UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

COBBLESTONE WIRELESS LLC,

Plaintiff,

V.

CISCO SYSTEMS, INC., 

Defendant.

Case No. 2:23-cv-00454-JRG-RSP 

LEAD CASE

JURY TRIAL DEMANDED

COBBLESTONE WIRELESS LLC,

Plaintiff,

V.

HEWLETT PACKARD ENTERPRISE

COMPANY and ARUBA NETWORKS, LLC, 

Defendant.

Case No. 2:23-cv-00457-JRG-RSP 

JURY TRIAL DEMANDED

PLAINTIFF COBBLESTONE WIRELESS LLC’S OPPOSITION TO

DEFENDANTS’ MOTION TO STAY PENDING INTER PARTES

REVIEW AND EX PARTE REEXAMINATION

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TABLE OF CONTENTS

i

I. INTRODUCTION ................................................................................................................. 4

II. LEGAL STANDARD ........................................................................................................... 5

III. ARGUMENT......................................................................................................................... 5

A. Any Simplification of the Issues that May Result from a Stay Is Speculative and 

Unlikely ........................................................................................................................ 5

1. The PTAB Has Not Instituted Defendants’ IPR Petition and Defendants’ 

Motion Should Thus Be Denied ......................................................................... 5

2. Ex Parte Reexamination of the ’802 Patent Is Unlikely to Result in Meaningful 

Simplification of the Issues ................................................................................ 6

3. Defendants’ Other Arguments Regarding Issue Simplification Are Without 

Merit ................................................................................................................... 8

B. Cobblestone Would Be Substantially Prejudiced by Delaying this Case for Years 

Until the IPR and EPR Proceedings Are Resolved ...................................................... 9

C. The Parties Have Already Invested Substantial Resources into This Case and Thus 

the Stage of the Case Does Not Support a Stay.......................................................... 11

IV. CONCLUSION.................................................................................................................... 13

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TABLE OF AUTHORITIES

ii

Cases

Cal. Inst. of Tech. v. Samsung Elecs. Co. Ltd.,

No. 2:21-CV-00446-JRG, Dkt. 108 (E.D. Tex. Jan. 20, 2023) ............................................ 9, 11

Cardware Inc. v. Samsung Elecs. Co., Ltd.,

No. 2:22-CV-00141-JRG-RSP, Dkt. 64 (E.D. Tex. Feb. 16, 2023) ........................................... 5

Chrimar Sys., Inc. v. Adtran, Inc.,

No. 6:15-CV-00618-JRG, 2016 WL 11746525 (E.D. Tex. Dec. 28, 2016)............................... 9

Comcast Cable Commc’ns Corp., LLC v. Finisar Corp.,

No. C 06-04206 WHA, 2007 WL 1052883 (N.D. Cal. Apr. 5, 2007)........................................ 4

EON Corp.IP Holdings, LLC v. Sensus USA Inc.,

No. 6:09-CV-116, 2009 WL 9506927 (E.D. Tex. Dec. 18, 2009) ........................................... 11

Image Processing Techs., LLC v. LG Elecs. Inc.,

No. 2:22-cv-00077-JRG-RSP, Dkt. 41 (E.D. Tex. Dec. 15, 2022)............................................. 5

KIPB LLC v. Samsung Elecs. Co.,

No. 2:19-cv-00056-JRG-RSP, 2019 WL 6173365 (E.D. Tex. Nov. 20, 2019)...................... 6, 7

Lennon Image Techs., LLC v. Macy’s Retail Holdings, Inc.,

No. 2:13-CV-00235-JRG, 2014 WL 4652117 (E.D. Tex. Sept. 18, 2014) ................................ 9

Longhorn HD LLC. v. NetScout Sys., Inc.,

No. 2:20-CV-00349-JRG, 2022 WL 71652 (E.D. Tex. Jan. 6, 2022).................................. 6, 11

Luminati Networks Ltd. v. Teso LT, UAB,

No. 2:19-CV-00395-JRG, 2020 WL 6803255 (E.D. Tex. Oct. 30, 2020).............................. 5, 6

MyPort, Inc. v. Samsung Electronics Co., Ltd.,

No. 2:22-43-CV-00114-JRG, Dkt. No. 73 (E.D. Tex. Jun. 13, 2023)........................................ 9

Netlist, Inc. v. Samsung Electronics Co. Ltd.,

No. 2:22-cv-00293-JRG, Dkt. 689 (E.D. Tex. Mar. 11, 2024)................................................... 9

Parallel Networks Licensing, LLC v. Ramquest Software, Inc.,

No. 4:19-CV-487, 2020 WL 1236266 (E.D. Tex. Mar. 13, 2020) ............................................. 4

Realtime Data LLC v. Actian Corp.,

No. 6:15-CV-463-RWS-JDL, 2016 WL 3277259 (E.D. Tex. June 14, 2016) ..................... 4, 11

Resonant Systems, Inc. v. Sony Group Corp.,

No. 2:22-cv-00424-JRG, Dkt. 84 (E.D. Tex. July 9, 2024)........................................................ 8

Solas OLED Ltd. v. Samsung Display Co., Ltd.,

No. 2:21-cv-00104-JRG, Dkt. 75 (E.D. Tex. Feb. 22, 2022) ................................................. 6, 7

Soverain Software LLC v. Amazon.Com, Inc.,

356 F. Supp. 2d 660 (E.D. Tex. 2005).................................................................................... 4, 6

Trover Grp., Inc. v. Dedicated Micros USA,

No. 2:13-CV-1047-WCB, 2015 WL 1069179 (E.D. Tex. Mar. 11, 2015)................................. 5

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iii

United Services Automobile Assoc. v. Truist Bank,

No. 2:22-cv-00291-JRG-RSP, Dkt. 70 (E.D. Tex. Mar. 22, 2023) ............................................ 5

Viavi Sols. Inc. v. Zhejiang Crystal-Optech Co.,

No. 2:21-CV-00378-JRG, 2022 WL 16856099 (E.D. Tex. Nov. 10, 2022)............................... 5

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I. INTRODUCTION

Defendants have failed to meet their burden to show that a stay pending inter partes review 

and ex parte reexamination is warranted. This Court has a “universal practice” of denying preinstitution motions to stay, and neither Defendants’ IPR petition nor the Samsung IPR has been 

instituted. The motion to stay should be denied on this basis alone. The mere fact that a third party 

reexam has been granted does not support deviating from this Court’s established practice, as 

Defendants have failed to identify any issues in this case that will be affected by the reexam. The 

lack of statutory estoppel for EPRs further undermines Defendants’ arguments regarding issue 

simplification. Defendants will be free to relitigate the same invalidity arguments in this case after 

the stay is lifted. Indeed, if there is even one surviving claim—which according to PTO statistics 

is far more likely than cancellation of all claims—the Court will still have to resolve claim 

construction, infringement, validity, and damages, among other issues. 

The other factors also weigh against a stay. EPRs typically take more than two years to 

reach resolution, and a final written decision in Defendants’ IPR (assuming institution) would not 

be expected until September 2025—after the June 2025 trial date. Defendants are also requesting 

a stay through any appeals, even if the petitioners lose their IPRs (if instituted), adding more

unnecessary delay. Further, discovery and claim construction are under way, and the parties and 

Court have already invested substantial resources into this case over the past 10 months since the 

complaint was filed. It would be far more efficient to move forward and proceed to trial as 

scheduled rather than indefinitely delay, potentially for several years, for the mere possibility that 

some of the issues will be simplified. 

Because all three factors weigh against a stay, Defendants’ motion should be denied.

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II. LEGAL STANDARD

“Courts have the inherent power to manage their dockets and stay proceedings.” Realtime 

Data LLC v. Actian Corp., No. 6:15-CV-463-RWS-JDL, 2016 WL 3277259, at *1 (E.D. Tex. June 

14, 2016). Accordingly, there is “no per se rule that patent cases should be stayed pending PTO 

proceedings, because such a rule ‘would invite parties to unilaterally derail litigation.’” Id.

(quoting Soverain Software LLC v. Amazon.Com, Inc., 356 F. Supp. 2d 660, 662 (E.D. Tex. 2005)); 

see also Comcast Cable Commc’ns Corp., LLC v. Finisar Corp., No. C 06-04206 WHA, 2007 WL 

1052883, at *1 (N.D. Cal. Apr. 5, 2007) (“If litigation were stayed every time a claim in suit 

undergoes reexamination, federal infringement actions would be dogged by fits and starts. Federal 

court calendars should not be hijacked in this manner.”). A stay is appropriate only where “the 

benefits of a stay outweigh the inherent costs of postponing resolution of the litigation.” Parallel 

Networks Licensing, LLC v. Ramquest Software, Inc., No. 4:19-CV-487, 2020 WL 1236266, at *4 

(E.D. Tex. Mar. 13, 2020).

In determining whether to grant a stay, courts consider three factors: (1) whether the stay 

would unduly prejudice or present a clear tactical disadvantage to the non-moving party; (2) 

whether a stay will simplify the issues in question and trial of the case; and (3) whether discovery 

is complete and whether a trial date has been set. Realtime, 2016 WL 3277259, at *1 (citing 

Soverain, 356 F. Supp. 2d at 662). As discussed below, all three factors weigh against a stay.

III. ARGUMENT

A. Any Simplification of the Issues that May Result from a Stay Is 

Speculative and Unlikely

1. The PTAB Has Not Instituted Defendants’ IPR Petition and 

Defendants’ Motion Should Thus Be Denied 

“[T]his Court has a consistent practice of denying motions to stay when the PTAB has yet 

to institute post-grant proceedings.” Luminati Networks Ltd. v. Teso LT, UAB, No. 2:19-CVCase 2:23-cv-00454-JRG-RSP Document 56 Filed 07/09/24 Page 6 of 15 PageID #: 314
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00395-JRG, 2020 WL 6803255, at *1 (E.D. Tex. Oct. 30, 2020); see also Trover Grp., Inc. v. 

Dedicated Micros USA, No. 2:13-CV-1047-WCB, 2015 WL 1069179, at *6 (E.D. Tex. Mar. 11, 

2015) (Bryson, J.) (“it is the universal practice” of courts in this District to deny pre-institution 

motions to stay); Viavi Sols. Inc. v. Zhejiang Crystal-Optech Co., No. 2:21-CV-00378-JRG, 2022 

WL 16856099, at *5 (E.D. Tex. Nov. 10, 2022) (“It is the Court’s established practice to consider 

that motions to stay pending IPR proceedings which have not been instituted are inherently 

premature and should be denied as such.”). That is because “[a]t this nascent stage of the PTAB 

proceedings, it is impossible for the Court to determine ‘whether the stay will likely result in 

simplifying the case before the court.’” Viavi, 2022 WL 16856099, at *5. “Indeed, if the PTAB 

denies institution of the IPRs, there will be no simplification of the case before the Court at all.” 

Id.

Here, Defendants filed IPR2024-00707 on March 19, 2024, and the PTAB is not expected 

to issue an institution decision until September 27, 2024. Defendants’ motion to stay should thus 

be denied as premature in accordance with this Court’s universal practice of denying pre-institution 

motions to stay.1

2. Ex Parte Reexamination of the ’802 Patent Is Unlikely to Result in 

Meaningful Simplification of the Issues

The ex parte reexamination filed by third party Unified Patents, LLC is unlikely to result 

in any meaningful simplification of the issues and does not support a stay. Indeed, Defendants 

have failed to specifically identify a single issue that may be affected by the reexam, and instead 

vaguely argue that there is a “substantial likelihood” that claims will either be canceled or 

1 This Court routinely denies pre-institution motions to stay without even considering the other 

stay factors. See, e.g., Image Processing Techs., LLC v. LG Elecs. Inc., No. 2:22-cv-00077-JRGRSP, Dkt. 41 (E.D. Tex. Dec. 15, 2022); Cardware Inc. v. Samsung Elecs. Co., Ltd., No. 2:22-

CV-00141-JRG-RSP, Dkt. 64 (E.D. Tex. Feb. 16, 2023); United Services Automobile Assoc. v. 

Truist Bank, No. 2:22-cv-00291-JRG-RSP, Dkt. 70 (E.D. Tex. Mar. 22, 2023).

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narrowed by amendment. Mot. at 8. But this Court has repeatedly rejected a “per se rule that patent 

cases should be stayed during reexamination because some of the relevant claims may be affected.” 

Soverain, 356 F. Supp. 2d at 662; see also Solas OLED Ltd. v. Samsung Display Co., Ltd., No. 

2:21-cv-00104-JRG, Dkt. 75 at 6 (E.D. Tex. Feb. 22, 2022) (“The Court declines to develop a per 

se rule that mere institution of an EPR results in a likelihood of simplification of the issues.”). To 

support a stay, Defendants must demonstrate that the merits of the reexam will “materially impact 

the parties’ positions or arguments in this case.” Longhorn HD LLC. v. NetScout Sys., Inc., No. 

2:20-CV-00349-JRG, 2022 WL 71652, at *3 (E.D. Tex. Jan. 6, 2022). Defendants’ generalized 

speculation about the statistical likelihood of cancellation or amendment, and the mere possibility 

of “having to re-do portions of discovery or claim construction” (Mot. at 8), falls far short of this 

burden. 

Furthermore, the PTO has yet to issue any office actions in the reexam. As explained by 

this Court, “[w]hile it is possible that all challenged claims could be canceled by the PTO, it is also 

entirely possible that [plaintiff] overcomes any eventual rejections through argument or 

insubstantial amendments.” Solas, Dkt. 75 at 5; see also Longhorn, 2022 WL 71652, at *3 n.4 

(explaining that it is “possible that [plaintiff] amends the claims in a way that has no bearing on 

this case,” or that plaintiff “persuades the PTO that the rejection is meritless, in which case the 

claims would remain unchanged”).2 Indeed, current PTO statistics also show that it is far more 

likely that the claims will be confirmed than canceled. See Ex Parte Reexamination Filing Data, 

https://www.uspto.gov/learning-and-resources/statistics/reexamination-information. “These 

2 See also KIPB LLC v. Samsung Elecs. Co., No. 2:19-cv-00056-JRG-RSP, 2019 WL 6173365, at 

*2 (E.D. Tex. Nov. 20, 2019) (explaining it is “not uncommon for claims to be initially rejected in 

the re-examination process” and finding simplification speculative where the PTO had issued a 

final office action rejecting all asserted claims and appeal was pending); Luminati, 2021 WL 

3128654, at *1, *4 (finding “low probability” of issue simplification and denying stay despite non- final rejections of all asserted claims).

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statistics cast serious doubt on the conclusion that an EPR—even where the claims have initially 

been rejected—will result in a simplification of the issues.” Longhorn, 2022 WL 71652, at *3 n.6.

And while it may be true that a large percentage of granted EPRs results in some changes to the 

claims, “there is no way to know how or if such changes are significant or minor.” Id. In light of 

these various potential outcomes of the reexam, “the Court cannot conclude, without engaging in 

improper speculation, that the [reexam] will ultimately simplify the issues in this case.” Id. at *3 

n.4.

The fact that Defendants are not subject to estoppel “also supports the conclusion that the 

[Unified Patents reexam] will not result in a simplification of the issues in this case.” Id. at *3 n.5; 

see also Solas, Dkt. 75 at 6 (“The lack of statutory estoppel with respect to EPRs, which would 

prevent [Defendants] from asserting the same prior art references and grounds of invalidity at trial 

as it asserts in the EPRs, also cautions against a likelihood of simplification of the issues.”); KIPB, 

2019 WL 6173365, at *2. Far from simplifying the issues, Defendants will be free to litigate the 

very same invalidity arguments in this Court after the stay is lifted. It would be far more efficient 

to let this case proceed as scheduled instead of imposing a years-long delay, with little if any 

benefit to the parties and the Court.

3. Defendants’ Other Arguments Regarding Issue Simplification Are 

Without Merit

Defendants’ reliance on the Samsung IPR petition (IPR2024-00606) fails for the same 

reasons discussed above: (1) the Samsung IPR has not been instituted (an institution decision is 

not expected until September 2024), and (2) Defendants have not agreed to be bound by estoppel 

with respect to the Samsung IPR. Thus, even assuming institution, there will be no simplification 

of the issues because Defendants will be free to relitigate validity based on the same grounds 

asserted in the Samsung IPR. See Resonant Systems, Inc. v. Sony Group Corp., No. 2:22-cv-00424-

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JRG, Dkt. 84 at 4 (E.D. Tex. July 9, 2024) (“Defendants’ refusal to be fully estopped by the 

Samsung IPRs further weighs against a stay here. Defendants should not be able to bootstrap off 

Samsung’s IPRs unless they are willing to be fully bound by the result.”).

Defendants’ reliance on the “earlier-filed” Samsung, Verizon, AT&T, and T-Mobile cases 

(Mot. at 8) is also unavailing. According to Defendants, the “Court’s claim construction orders 

related to the ’802 Patent in the Samsung Case and Carrier Cases will likely inform claim 

construction issues in the instant cases and significantly simplify Defendants’ trials.” Id. This fails 

for multiple reasons.

First, Defendants have failed to identify a single claim construction issue in the Samsung 

and carrier cases that will affect this case. Second, even assuming there are overlapping issues, 

Defendants have not agreed to be bound by the Court’s constructions in the Samsung and carrier 

cases—or any of the Court’s findings in those cases, for that matter. And third, the issue at hand 

is whether the pending IPR and EPR proceedings will result in issue simplification—not whether 

the “parties and the Court will potentially benefit from having guidance” from co-pending district 

court cases. Mot. at 9. Defendants fail to cite a single case supporting that the mere existence of 

co-pending litigation involving an overlapping patent supports a stay pending IPR/EPR.

B. Cobblestone Would Be Substantially Prejudiced by Delaying this Case

for Years Until the IPR and EPR Proceedings Are Resolved

This case has been pending for nearly 10 months, and delaying resolution of Cobblestone’s

patent infringement claims for multiple years until the IPR and EPR proceedings and any appeals

are concluded would substantially prejudice Cobblestone. The mere fact that Cobblestone is 

seeking only monetary damages does not preclude it from being prejudiced by a stay. This Court 

has repeatedly rejected this exact argument and recognized that “a patent holder has ‘an interest in 

the timely enforcement of its patent right.’” Lennon Image Techs., LLC v. Macy’s Retail Holdings, 

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Inc., No. 2:13-CV-00235-JRG, 2014 WL 4652117, at *2 (E.D. Tex. Sept. 18, 2014); see also 

Netlist, Inc. v. Samsung Electronics Co. Ltd., No. 2:22-cv-00293-JRG, Dkt. 689 at 4 (E.D. Tex. 

Mar. 11, 2024) (“The fact that Netlist is seeking solely monetary damages does not mean that 

Netlist cannot be prejudiced by a significant delay of an imminent trial date.”); Chrimar Sys., Inc. 

v. Adtran, Inc., No. 6:15-CV-00618-JRG, 2016 WL 11746525, at *1 (E.D. Tex. Dec. 28, 2016)

(“Defendants’ argument suggests that only those parties who seek injunctions could ever 

experience undue prejudice from the delay of the final resolution of their case. This cannot be the 

case.”). Cobblestone will be “prejudiced by a delay in its ability to vindicate its patent rights caused 

by a stay, which weighs against granting this Motion.” Cal. Inst. of Tech. v. Samsung Elecs. Co. 

Ltd., No. 2:21-CV-00446-JRG, Dkt. 108 at 3 (E.D. Tex. Jan. 20, 2023).

For example, in MyPort, Inc. v. Samsung Electronics Co., Ltd., No. 2:22-43-CV-00114-

JRG, Dkt. No. 73 (E.D. Tex. Jun. 13, 2023), the Court found that plaintiff “has an interest in the 

timely enforcement of its patent rights.” Id. at 4. The Court found this factor weighed against a 

stay because it “could delay the case by nearly two years” and “the PTAB decision is not due until 

over two months after jury trial is set to begin.” Id. The Court further noted that “the fact that a 

plaintiff seeks a monetary recovery from a well-heeled defendant does not mean, ipso facto, that a 

lengthy delay in adjudicating the plaintiff’s patent rights does it no prejudice.” Id. at 4 n.2. The 

Court thus denied the stay even though, unlike here, the IPRs had been instituted. The same 

reasoning applies here. The IPR and EPR proceedings will likely delay this case by more than two 

years given that EPRs on average take over 25 months. The delay will be even longer if 

Defendants’ request that the stay include any appeals is granted. In addition, a final written 

decision in Defendants’ IPR would not be expected until September 2025—three months after the 

June 2025 trial date. This factor strongly weighs against a stay.

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Defendants’ arguments regarding the volume of documents produced by Cobblestone and 

the stage of discovery (Mot. at 5–6) pertain to the stage of the case, discussed below, and are 

irrelevant to the prejudice Cobblestone would suffer in the event of a stay. In any event, it should 

come as no surprise that Cobblestone, the plaintiff and patent owner, has limited documentation. 

In patent cases, the bulk of relevant documents typically comes from the accused infringers. Under 

Defendants’ logic, patentees can never be prejudiced by a stay because they typically do not 

produce a high volume of documents. This argument should be rejected.

C. The Parties Have Already Invested Substantial Resources into This 

Case and Thus the Stage of the Case Does Not Support a Stay

Cobblestone filed its complaint against 10 months ago in September 2023. Since then, the 

parties and Court have invested substantial resources into this case. The Court has held a 

scheduling conference and issued a docket control order, protective order, discovery order, and ediscovery order. Discovery is under way—the parties have produced documents and exchanged 

initial disclosures, written discovery, and infringement and invalidity contentions. To date, the 

parties have collectively produced over 300,000 pages of documents, and have propounded more 

than 30 interrogatories, all of which have been responded to. Document production will be 

“substantially complete[d]” by October 15, 2024, shortly after the institution deadline. Dkt. 37 at 

4.

Claim construction has also begun, as the parties are due to exchange proposed claim terms 

on the date of this opposition brief. Id. at 5. Claim construction discovery will be completed and 

opening claim construction briefs will have been served before the institution deadline for 

Defendants’ IPR. Id. at 4–5.

Notably, Defendants waited until March 2024 to file their IPR petition—six months after 

this case was filed and three months after Cobblestone served infringement contentions identifying 

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the asserted claims. Defendants have no explanation for this delay. Realtime, 2016 WL 3277259, 

at *3 (finding defendants’ “lack of diligence” in filing IPR petitions seven months after the case 

was filed, without any “explanation for this unjustifiable delay,” weighed against a stay). 

The PTAB’s institution decision is thus not expected until September 2024, and final 

written decisions are not expected until September 2025 (and could come as late as March 2026)—

well after the June 2025 trial in this case. See Resonant, Dkt. 84 at 5 (denying stay where 

“Defendants’ delay has necessarily extended the potential resolution of the IPRs until well after 

the scheduled trial date”). Staying the case now, in the midst of discovery and claim construction, 

would be inefficient and wasteful. This factor weighs against a stay. See Longhorn, 2022 WL 

71652, at *4 (“Although it is true that the parties, and the Court, will still invest additional 

resources in this case, all dates for remaining case events—including trial—have been set and the 

Court intends to maintain those dates. Accordingly, the Court finds this factor does not favor a 

stay.”); Cal. Tech., Dkt. 108 at 5 (finding this factor weighed against a stay where the parties had 

engaged in discovery, exchanged contentions, and, as of the date of the order, had begun the claim 

construction process and were “nearing competition of document production”); EON Corp.IP 

Holdings, LLC v. Sensus USA Inc., No. 6:09-CV-116, 2009 WL 9506927, at *4 (E.D. Tex. Dec. 

18, 2009) (“Although this case is in its early stages, it is not early as to weigh in favor of a stay” 

where the complaint was filed six months ago, the “parties in this case have begun the discovery 

process,” and plaintiff “has completed its P.R. 3–1 and 3–2 disclosures”). 

Defendants’ assertion that “this Court may consider statements made in the [IPR and 

reexam] proceedings as part of the prosecution history in construing the parties’ disputed claim 

terms” (Mot. at 7) is pure speculation and should be rejected. Defendants have not identified any 

claim construction issues in this case that may be affected by the IPR or reexam. Indeed, 

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Defendants’ IPR petition does not seek construction of any term. Defendants instead take the 

position that “no specific construction of any claim term is required.” IPR2024-00707, Paper 3 at 

10. The IPR is thus unlikely to have any bearing on claim construction in this case at all.

This factor weighs against a stay.

IV. CONCLUSION

For the foregoing reasons, Defendants’ motion to stay should be denied.

Dated: July 9, 2024 Respectfully submitted,

/s/ Reza Mirzaie

Reza Mirzaie

CA State Bar No. 246953

Marc A. Fenster

CA State Bar No. 181067

Neil A. Rubin

CA State Bar No. 250761

Christian W. Conkle

CA State Bar No. 306374

Jonathan Ma

CA State Bar No. 312773

RUSS AUGUST & KABAT

12424 Wilshire Boulevard, 12th Floor

Los Angeles, CA 90025

Telephone: 310-826-7474

Email: rmirzaie@raklaw.com

Email: mfenster@raklaw.com

Email: nrubin@raklaw.com

Email: cconkle@raklaw.com

Email: jma@raklaw.com

Attorneys for Plaintiff

Cobblestone Wireless LLC

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CERTIFICATE OF SERVICE

I hereby certify that on July 9, 2024, I electronically filed the foregoing document with the 

Clerk of the Court for the Eastern District of Texas using the ECF System which will send 

notification to the registered participants of the ECF System as listed on the Court’s Notice of 

Electronic Filing.

/s/ Reza Mirzaie

Reza Mirzaie 

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