IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION 

Valtrus Innovations Ltd. 

Plaintiff 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

v. 

AT&T Inc., AT&T Services, Inc., AT&T 

Mobility LLC, and AT&T Corp. 

Defendants. 

CIVIL ACTION NO. 2:23cv443 

 JURY TRIAL DEMANDED 

COMPLAINT FOR PATENT INFRINGEMENT AND JURY DEMAND 

Plaintiff Valtrus Innovations Limited (“Plaintiff” or “Valtrus”), by and through its undersigned 

counsel, brings this complaint for patent infringement and damages against Defendants AT&T Inc., 

AT&T Services, Inc., AT&T Mobility LLC, and AT&T Corp. (collectively, “AT&T” or 

“Defendants”) and would respectfully show the Court as follows: 

PARTIES 

1. Valtrus is the successor-in-interest to a substantial patent portfolio created by Hewlett Packard 

Enterprise and its predecessor companies (collectively, “HPE”). Valtrus is an Irish entity duly 

organized and existing under the laws of the Republic of Ireland. The address of the registered 

office of Valtrus is: The Glasshouses GH2, 92 Georges Street Lower, Dun Laoghaire, Dublin 

A96 VR66, Ireland. HPE’s worldwide corporate headquarters is located in Houston, Texas. 

One of HPE’s primary U.S. facilities is located in Plano, Texas. 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 1 of 25 PageID #: 1
2. On information and belief, AT&T Inc. is a corporation organized under the laws of the State of 

Delaware, with its principal place of business at 208 S. Akard Street, Dallas, Texas 75202. 

AT&T Inc. has a registered agent for service, CT Corporation System, located at 1999 Bryan 

Street, Suite 900, Dallas, TX 75201. 

3. On information and belief, AT&T Services, Inc. is a corporation organized and existing under 

the laws of the State of Delaware, with a principal place of business at 208 South Akard St., 

Dallas, Texas, 75202. 

4. On information and belief, AT&T Mobility LLC is a limited liability company organized and 

existing under the law of Delaware, with its principal place of business at 1025 Lenox Park 

Boulevard NE, Atlanta, Georgia 30319. 

5. On information and belief, AT&T Corp. is a corporation organized and existing under the laws 

of the State of New York, with a principal place of business at One AT&T Way, Bedminster, 

New Jersey 07921-0752. 

6. On information and belief, AT&T owns and operates a foundry at 2900 W. Plano Parkway, 

Plano, Texas 75075. On information and belief, AT&T also operates an office at 3400 W. Plano 

Parkway, Plano, Texas 75075. 

PATENTS IN SUIT 

7. Valtrus is the assignee of and owns all right and title to U.S. Patent Nos. 7,599,379 (the “’379 

Patent”); 7,769,050 (the “’050 Patent”); 7,130,625 (the “’625 Patent”); 8,307,063 (the “’063 

Patent”); 6,781,858 (the “‘858 Patent”); 6,871,264 (the “‘264 Patent”); 8,432,892 (the “‘892 

Patent”); 7,490,155 (the “‘155 Patent”); 7,930,539 (the “‘539 Patent”) and 7,085,364 (the 

“’364 Patent”) (collectively, “the Asserted Patents”). On information and belief, Valtrus is not 

subject to the limitations of 35 U.S.C. § 287. 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 2 of 25 PageID #: 2
8. The Asserted Patents were developed by inventors working for HPE. HPE and its predecessors 

have developed numerous innovative and diverse technologies, including groundbreaking 

inventions pertaining to wireless architectures and communication techniques, as well as 

semiconductor designs. 

9. The ’379 Patent, entitled Registering Stations Between Protocols, was duly and lawfully issued 

on October 6, 2009. A true and correct copy of the ’379 Patent is attached hereto as Exhibit 1. 

10. The ’379 Patent has been in full force and effect since its issuance. Valtrus owns by assignment 

the entire right and title in and to the ’379 Patent, including the right to seek damages for any 

infringement thereof. 

11. The ’050 Patent, entitled System and Method for Interference Mitigation for Wireless 

Communication, was duly and lawfully issued on August 3, 2010. A true and correct copy of 

the ’050 Patent is attached hereto as Exhibit 2. 

12. The ’050 Patent has been in full force and effect since its issuance. Valtrus owns by assignment 

the entire right and title in and to the ’050 Patent, including the right to seek damages for any 

infringement thereof. 

13. The ’625 Patent, entitled System and Method for a Universal Wireless Access Gateway, was 

duly and lawfully issued on October 31, 2006. A true and correct copy of the ’625 Patent is 

attached hereto as Exhibit 3. 

14. The ’625 Patent has been in full force and effect since its issuance. Valtrus owns by assignment 

the entire right and title in and to the ’625 Patent, including the right to seek damages for any 

infringement thereof. 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 3 of 25 PageID #: 3
15. The ’063 Patent, entitled Method and Apparatus for Managing Data Traffic Associated with a 

User on a Network, was duly and lawfully issued on November 6, 2012. A true and correct 

copy of the ’063 Patent is attached hereto as Exhibit 4. 

16. The ’063 Patent has been in full force and effect since its issuance. Valtrus owns by assignment 

the entire right and title in and to the ’063 Patent, including the right to seek damages for any 

infringement thereof. 

17. The ’858 Patent, entitled Cubic Memory Array, was duly and lawfully issued on August 24, 

2004. A true and correct copy of the ’858 Patent is attached hereto as Exhibit 5. 

18. The ’858 Patent has been in full force and effect from its issuance until its expiration. Valtrus 

owns by assignment the entire right and title in and to the ’858 Patent, including the right to 

seek damages for any infringement thereof. 

19. The ’264 Patent, entitled System and Method for Dynamic Processor Core and Cache 

Partitioning on Large-Scale Multithreaded, Multiprocessor Integrated Circuits, was duly and 

lawfully issued on March 22, 2005. A true and correct copy of the ’264 Patent is attached 

hereto as Exhibit 6. 

20. The ’264 Patent has been in full force and effect from its issuance until its expiration. Valtrus 

owns by assignment the entire right and title in and to the ’264 Patent, including the right to 

seek damages for any infringement thereof. 

21. The ’892 Patent, entitled Method and System for WLAN Synchronization, was duly and 

lawfully issued on April 30, 2013. A true and correct copy of the ’892 Patent is attached hereto 

as Exhibit 7. 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 4 of 25 PageID #: 4
22. The ’892 Patent has been in full force and effect since its issuance. Valtrus owns by assignment 

the entire right and title in and to the ’892 Patent, including the right to seek damages for any 

infringement thereof. 

23. The ’155 Patent, entitled Management and Control for Interactive Media Sessions, was duly 

and lawfully issued on February 10, 2009. A true and correct copy of the ’155 Patent is attached 

hereto as Exhibit 8. 

24. The ’155 Patent has been in full force and effect since its issuance. Valtrus owns by assignment 

the entire right and title in and to the ’155 Patent, including the right to seek damages for any 

infringement thereof. 

25. The ’539 Patent, entitled Computer System Resource Access Control, was duly and lawfully 

issued on April 19, 2011. A true and correct copy of the ’539 Patent is attached hereto as Exhibit 

9. 

26. The ’539 Patent has been in full force and effect since its issuance. Valtrus owns by assignment 

the entire right and title in and to the ’539 Patent, including the right to seek damages for any 

infringement thereof. 

27. The ’364 Patent, entitled Advanced Conference Drop, was duly and lawfully issued on August 

1, 2006. A true and correct copy of the ’364 Patent is attached hereto as Exhibit 10. 

28. The ’364 Patent has been in full force and effect from its issuance until its expiration. Valtrus 

owns by assignment the entire right and title in and to the ’364 Patent, including the right to 

seek damages for any infringement thereof. 

JURISDICTION AND VENUE 

29. Valtrus incorporates by reference paragraphs 1-28 herein. 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 5 of 25 PageID #: 5
30. This civil action arises under the patent laws of the United States, 35 U.S.C. § 1 et seq., 

including without limitation 35 U.S.C. §§ 271, 281, 283, 284, and 285. This is a patent 

infringement lawsuit over which this Court has subject matter jurisdiction under, inter alia, 28 

U.S.C. §§ 1331, 1332, and 1338(a). 

31. This District has general and specific personal jurisdiction over Defendants because, directly 

or through intermediaries, Defendants have committed acts within this District giving rise to 

this action; are present in and transact and conduct business, directly, and/or indirectly, in this 

District and the State of Texas; and transact and conduct business with residents of this District 

and the State of Texas. 

32. Defendants are registered with the Secretary of State to do business in the State of Texas. 

Defendants sell and offer to sell products and services throughout the State of Texas, including 

in this judicial district, and introduce infringing products and services into the stream of 

commerce knowing that they would be sold in the State of Texas and this judicial district. 

33. Valtrus’s causes of action arise, at least in part, from Defendants’ contacts with and activities 

in and/or directed at this District and the State of Texas. 

34. Defendants have infringed the Asserted Patents within this District and the State of Texas by 

making, using, selling, offering for sale, and/or importing in or into this District and elsewhere 

in the State of Texas, products and services claimed by the Asserted Patents, including without 

limitation products that, when made or used, practice the claimed methods of the Asserted 

Patents. Defendants, directly and through intermediaries, make, use, sell, offer for sale, import, 

ship, distribute, advertise, promote, and/or otherwise commercialize such infringing products 

and services in or into this District and the State of Texas. Defendants regularly conduct and 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 6 of 25 PageID #: 6
solicit business in, engage in other persistent courses of conduct in, and/or derive substantial 

revenue from goods and services provided to residents of this District and the State of Texas. 

35. This Court has personal jurisdiction over Defendants pursuant to TEX. CIV. PRAC. & REM.

CODE § 17.041 et seq.

36. Venue is proper in this District under 28 U.S.C. §§ 1391(b)-(c) and 1400(b). 

37. Defendants are registered to do business in Texas. Additionally, upon information and belief, 

Defendants have transacted business in this District and have committed acts of direct and 

indirect infringement in this District, by, among other things, making, using, offering to sell, 

selling, and importing products that infringe the Asserted Patents, and/or taking actions in this 

District that induce and/or contribute to infringement of the Asserted Patents. Moreover, on 

information and belief, Defendants have regular and established places of business in this 

District, including at (1) 2900 W. Plano Parkway, Plano, Texas 75075; (2) 3400 W. Plano 

Parkway, Texas 75075; and (3) 12244 FM 423 #400, Frisco, TX 75034. 

38. Each Defendant makes, uses, sells, offers to sell, and/or imports infringing products into and/or 

within this District, maintains a permanent and/or continuing presence within this District, and 

has the requisite minimum contacts with this District such that this venue is a fair and 

reasonable one. Upon information and belief, each Defendant has transacted and, at the time 

of the filing of the Complaint, is continuing to transact business within this District. 

FIRST CLAIM 

(Infringement of the ’379 Patent) 

39. Valtrus re-alleges and incorporates herein by reference paragraphs 1-38 of its Complaint. 

40. The ’379 Patent is generally directed to a wireless architecture with an interoperability node 

operable to consolidate a registration process across multiple different network protocols. 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 7 of 25 PageID #: 7
41. Defendants have been on notice of the ’379 Patent and a specific factual basis for their 

infringement of the ’379 Patent since at least on or about January 5, 2022. On information and 

belief, Defendants have not taken any action to stop their infringement. 

42. Defendants have, under 35 U.S.C. § 271(a), directly infringed, and continue to directly 

infringe, literally and/or under the doctrine of equivalents, one or more claims, including 

without limitation at least claim 7 of the ’379 Patent, by making, using, testing, selling, offering 

for sale, and/or importing hardware and/or software including components operable to 

communicate and register devices on networks such as LTE and IP Multimedia Subsystem 

(excluding any products licensed under the ’379 Patent). For example, AT&T makes, uses, 

tests, operates, sells, offers for sale, and/or imports hardware and/or software enabling 

communications via LTE and IP Multimedia Subsystem networks and that communicate with 

multiple different network protocols, consolidate the registration process on multiple different 

network protocols, and register a station in one or more other network types. An exemplary 

claim chart concerning one way in which AT&T infringes claim 7 of the ’379 Patent is attached 

as Exhibit 11. 

43. Defendants also indirectly infringed, and continue to indirectly infringe, the ’379 Patent under 

35 U.S.C. § 271(b) and (c). 

44. Defendants knowingly and intentionally actively aided, abetted, and induced others to directly 

infringe at least claim 7 of the ’379 Patent (such as their customers in this District and 

throughout the United States) by, for example, advertising to customers and encouraging them 

to use AT&T’s service because of its robustness and availability over multiple networks.1

 

1 See, e.g., 

https://about.att.com/content/dam/snrdocs/7_Tenets_of_ATTs_Network_Transformation_White_

Paper.pdf at p. 7 (last visited September 26, 2023). 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 8 of 25 PageID #: 8
AT&T further advertises that mobile devices, such as the Motorola moto g stylus 5G, can 

communicate over multiple network types.2

 Moreover, Valtrus put AT&T on notice of its 

infringement of the ’379 Patent no later than on or about January 5, 2022. 

45. Defendants contribute to the direct infringement of at least claim 7 of the ’379 Patent under 35 

U.S.C. § 271(c) by supplying, with knowledge of the ’379 Patent, a material part of a claimed 

invention, where the material part is not a staple article of commerce and is incapable of 

substantial noninfringing use. For example, the identified interoperability node (per the claim 

chart) is a material part of the claimed invention, is not a staple article of commerce, and is 

incapable of substantial non-infringing uses. 

46. Defendants’ infringement has been willful in view of the above, and their failure to take any 

action, even after being put on notice, to stop their infringement or inducement of, or 

contribution to, infringement by others. 

SECOND CLAIM 

(Infringement of the ’050 Patent) 

47. Valtrus re-alleges and incorporates herein by reference paragraphs 1-46 of its Complaint. 

48. The ’050 Patent is generally directed to systems and methods for interference mitigation in 

wireless communications. 

49. Defendants have been on notice of the ’050 Patent and a specific factual basis for their 

infringement of the ’050 Patent since at least on or about January 5, 2022. On information and 

belief, Defendants have not taken any action to stop their infringement. 

2 See, e.g., https://www.att.com/buy/phones/moto-g-stylus-5g-2022.html (last visited September 

26, 2023); https://www.att.com/scmsassets/support/wireless/motogstylus5g-2023-na-retail-ugen-us.ssc8d89533-a.pdf (Messaging apps section) (last visited September 26, 2023). 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 9 of 25 PageID #: 9
50. Defendants have, under 35 U.S.C. § 271(a), directly infringed, and continue to directly 

infringe, literally and/or under the doctrine of equivalents, one or more claims, including 

without limitation at least claim 1 of the ’050 Patent, by making, using, testing, selling, leasing, 

offering for sale, and/or importing broadband gateway products, including, for example, the 

BGW320 and other WiFi6 enabled products, which, when operated, perform the method of 

claim 1 of the ’050 Patent (excluding any products licensed under the ’050 Patent). An 

exemplary claim chart concerning AT&T’s infringement of claim 1 of the ’050 Patent is 

attached as Exhibit 12. 

51. Defendants also indirectly infringed, and continue to indirectly infringe, the ’050 Patent under 

35 U.S.C. § 271(b) and (c). 

52. Defendants knowingly and intentionally actively aided, abetted, and induced others to directly 

infringe at least claim 1 of the ’050 Patent (such as their customers in this District and 

throughout the United States) by, for example, selling the accused products (such as the 

BGW320) and encouraging their customers to create infringing Wi-Fi networks.3

 Moreover, 

Valtrus put AT&T on notice of the basis for its infringement (and infringement by customers) 

of the ’050 Patent no later than on or about January 5, 2022. 

53. Defendants contribute to the direct infringement of at least claim 1 of the ’050 Patent under 35 

U.S.C. § 271(c) by supplying, with knowledge of the ’050 Patent, a material part of a claimed 

invention, where the material part is not a staple article of commerce and is incapable of 

substantial noninfringing use. For example, operation of the BGW320 is a material part of the 

claimed invention, is not a staple article of commerce, and is incapable of substantial noninfringing uses. 

3 See, e.g., https://www.att.com/wi-fi/ (last visited September 26, 2023). 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 10 of 25 PageID #: 10
54. Defendants’ infringement has been willful in view of the above, and their failure to take any 

action, even after being put on notice, to stop their infringement or inducement of, or 

contribution to, infringement by others. 

THIRD CLAIM 

(Infringement of the ’625 Patent) 

55. Valtrus re-alleges and incorporates herein by reference paragraphs 1-54 of its Complaint. 

56. The ’625 Patent is generally directed to a universal wireless access gateway and methods for 

using the same. 

57. Defendants have been on notice of the ’625 Patent and a specific factual basis for their 

infringement of the ’625 Patent since at least on or about January 5, 2022. On information and 

belief, Defendants have not taken any action to stop their infringement. 

58. Defendants have, under 35 U.S.C. § 271(a), directly infringed, and continue to directly 

infringe, literally and/or under the doctrine of equivalents, one or more claims, including 

without limitation at least claim 16 of the ’625 Patent, by making, using, testing, selling, 

leasing, offering for sale, and/or importing hardware and software used in the cellular, Wi-Fi, 

and IP Multimedia System networks, and by offering access to those networks (excluding any 

products licensed under the ’625 Patent). An exemplary claim chart concerning one way in 

which AT&T infringes claim 16 of the ’625 Patent is attached as Exhibit 13. 

59. Defendants also indirectly infringed, and continue to indirectly infringe, the ’625 Patent under 

35 U.S.C. § 271(b) and (c). 

60. Defendants knowingly and intentionally actively aided, abetted, and induced others to directly 

infringe at least claim 16 of the ’625 Patent (such as their customers in this District and 

throughout the United States) by, for example, offering access to (and encouraging use of) the 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 11 of 25 PageID #: 11
cellular and Wi-Fi networks. For instance, AT&T advertises Wi-Fi calling and provides 

customers with instructions on how to use it and background information about the same.4

 

Moreover, Valtrus put AT&T on notice of its infringement of the ’625 Patent no later than on 

or about January 5, 2022. 

61. Defendants contribute to the direct infringement of at least claim 16 of the ’625 Patent under 

35 U.S.C. § 271(c) by supplying, with knowledge of the ’625 Patent, a material part of a 

claimed invention, where the material part is not a staple article of commerce and is incapable 

of substantial noninfringing use. For example, AT&T provides, owns, operates, sells, offers to 

sell, leases, uses, and/or imports various hardware and software enabling access to the cellular, 

Wi-Fi, and IP Multimedia System networks (such as that shown in Exhibit 13) that are not 

staple articles of commerce and are incapable of substantial non-infringing uses. Accordingly, 

even if AT&T does not provide, own, operate, sell, offer to sell, lease, and/or import all of the 

hardware and software involved in the claimed system, it is still contributing to the 

infringement of others, including customers. 

62. Defendants’ infringement has been willful in view of the above, and their failure to take any 

action, even after being put on notice, to stop their infringement or inducement of, or 

contribution to, infringement by others. 

FOURTH CLAIM 

(Infringement of the ’063 Patent) 

63. Valtrus re-alleges and incorporates herein by reference paragraphs 1-62 of its Complaint. 

4 See, e.g., https://www.att.com/support/article/wireless/KM1063258 (last visited September 26, 

2023) 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 12 of 25 PageID #: 12
64. The ’063 Patent is generally directed to systems and methods for managing network data 

traffic. 

65. Defendants have been on notice of the ’063 Patent and a specific factual basis for their 

infringement of the ’063 Patent since at least on or about August 26, 2022. On information 

and belief, the AT&T Defendants have not taken any action to stop their infringement. 

66. Defendants have, under 35 U.S.C. § 271(a), directly infringed, and continue to directly 

infringe, literally and/or under the doctrine of equivalents, one or more claims, including 

without limitation at least claim 1 of the ’063 Patent, by making, using, testing, selling, leasing, 

offering for sale, and/or importing networks and network switches that provide for the control 

of user high-speed data across the cellular network (excluding any products licensed under the 

’063 Patent). An exemplary claim chart concerning one way in which AT&T infringes claim 

1 of the ’063 Patent is attached as Exhibit 14. 

67. Defendants also indirectly infringed, and continue to indirectly infringe, the ’063 Patent under 

35 U.S.C. § 271(b) and (c). 

68. Defendants knowingly, intentionally actively aided, abetted, and induced others to directly 

infringe at least claim 1 of the ’063 Patent by, for example, offering access to (and encouraging 

use of) the wireless networks. For instance, AT&T advertises that data rates are reduced based 

on certain parameters and users may not be allowed to access high-speed data networks after 

reaching certain data volume usage. See Exhibit 14. Moreover, Valtrus put AT&T on notice 

of its infringement of the ’063 Patent no later than on or about August 26, 2022. 

69. Defendants contribute to the direct infringement of at least claim 1 of the ’063 Patent under 35 

U.S.C. § 271(c) by supplying, with knowledge of the ’063 Patent, a material part of a claimed 

invention, where the material part is not a staple article of commerce and is incapable of 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 13 of 25 PageID #: 13
substantial noninfringing use. For example, Defendants provide, own, operate, sell, offer to 

sell, lease, and/or import various hardware and software enabling access to the wireless 

networks and components (such as that shown in Exhibit 14) that are not a staple article of 

commerce and are incapable of substantial noninfringing use. Accordingly, even if AT&T does 

not provide, own, operate, sell, offer to sell, lease, and/or import all of the hardware and 

software involved in the claimed system, it is still contributing to the infringement of others, 

including customers. 

70. Defendants’ infringement has been willful in view of the above, and their failure to take any 

action, even after being put on notice, to stop their infringement or inducement of, or 

contribution to, infringement by others. 

FIFTH CLAIM 

 (Infringement of the ’858 Patent) 

71. Valtrus re-alleges and incorporates herein by reference paragraphs 1-70 of its Complaint. 

72. The ’858 Patent is generally directed to a cubic memory array. 

73. Defendants have been on notice of the ’858 Patent and a specific factual basis for their 

infringement of the ’858 Patent since at least on or about January 5, 2022. On information and 

belief, Defendants did not take any action to stop their infringement. 

74. Defendants have, under 35 U.S.C. § 271(a), directly infringed, literally and/or under the 

doctrine of equivalents, one or more claims, including without limitation at least claim 21 of 

the ’858 Patent, by using, testing, selling, leasing, offering for sale, and/or importing mobile 

devices containing the claimed cubic memory array (excluding any products licensed under 

the ’858 Patent). For example, AT&T has tested, imported, sold, used, and/or offered for sale 

Lenovo moto g POWER phones with Micron/Intel 96L 20nm 3D NAND flash memory. An 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 14 of 25 PageID #: 14
exemplary claim chart concerning one way in which AT&T infringed claim 21 of the ’858 

Patent is attached as Exhibit 15. 

75. Defendants’ infringement has been willful in view of the above, and their failure to take any 

action, even after being put on notice, to stop their infringement. 

SIXTH CLAIM 

(Infringement of the ’264 Patent) 

76. Valtrus re-alleges and incorporates herein by reference paragraphs 1-75 of its Complaint. 

77. The ’264 Patent is generally directed to systems and methods for dynamic processor core and 

cache partitioning. 

78. Defendants have been on notice of the ’264 Patent and a specific factual basis for their 

infringement of the ’264 Patent since at least on or about January 5, 2022. On information and 

belief, Defendants did not take any action to stop their infringement. 

79. Defendants have, under 35 U.S.C. § 271(a), directly infringed, literally and/or under the 

doctrine of equivalents, one or more claims, including without limitation at least claim 1 of the 

’264 Patent, by using, testing, selling, leasing, offering for sale, and/or importing mobile 

devices with ARM-based processors supporting DynamIQ Shared Units (excluding any 

products licensed under the ’264 Patent). For example, AT&T has sold, offered for sale, used 

and tested Lenovo devices including the Moto Edge that contain A55 CPUs. An exemplary 

claim chart concerning one way in which AT&T infringed claim 1 of the ’264 Patent is attached 

as Exhibit 16. 

80. Defendants have also indirectly infringed the ’264 Patent under 35 U.S.C. § 271(b) and (c). 

81. Defendants knowingly and intentionally actively aided, abetted, and induced others to directly 

infringe at least claim 1 of the ’264 Patent (such as their customers in this District and 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 15 of 25 PageID #: 15
throughout the United States) by, for example, selling, offering for sale, and encouraging 

customers to use mobile devices with infringing chips. Moreover, Valtrus put AT&T on notice 

of its infringement of the ’264 Patent no later than on or about January 5, 2022. 

82. Defendants contributed to the direct infringement of at least claim 1 of the ‘264 Patent under 

35 U.S.C. § 271(c) by supplying, with knowledge of the ‘264 Patent, a material part of a 

claimed invention, where the material part is not a staple article of commerce and is incapable 

of substantial noninfringing use. For example, the identified ARM-based processor supporting 

DynamIQ Shared Units (per the claim chart) is a material part of the claimed invention, is not 

a staple article of commerce, and is incapable of substantial non-infringing uses. Additionally, 

AT&T sold Lenovo mobile devices including those noted above that contain Qualcomm 

Snapdragon 870 chips (and/or similar chips in the Snapdragon 8xx family), which, when used, 

form a material part of the invention, where the material part is not a staple article of commerce 

and is incapable of substantial non-infringing use. 

83. Defendants’ infringement has been willful in view of the above, and their failure to take any 

action, even after being put on notice, to stop their infringement or inducement of, or 

contribution to, infringement by others. 

SEVENTH CLAIM 

(Infringement of the ’892 Patent) 

84. Valtrus re-alleges and incorporates herein by reference paragraphs 1-83 of its Complaint. 

85. The ’892 Patent is generally directed to methods and systems for synchronizing access points 

within a wireless local area network. 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 16 of 25 PageID #: 16
86. Defendants have been on notice of the ’892 Patent and a specific factual basis for their 

infringement of the ’892 Patent since at least on or about April 21, 2023. On information and 

belief, Defendants have not taken any action to stop their infringement. 

87. Defendants have, under 35 U.S.C. § 271(a), directly infringed, and continue to directly 

infringe, literally and/or under the doctrine of equivalents, one or more claims, including 

without limitation at least claim 10 of the ’892 Patent, by using, testing, selling, leasing, 

offering for sale, and/or importing mesh network systems comprising access points (excluding 

any products licensed under the ’892 Patent). For example, AT&T has sold, offered for sale, 

imported, used and tested access points and mesh network Wi-Fi extenders such as AT&T 

AirTies. An exemplary claim chart concerning one way in which AT&T infringes claim 10 of 

the ’892 Patent is attached as Exhibit 17. 

88. Defendants also indirectly infringed, and continue to indirectly infringe, the ’892 Patent under 

35 U.S.C. § 271(b) and (c). 

89. Defendants are knowingly and intentionally actively aiding, abetting, and inducing others to 

directly infringe at least claim 10 of the ’892 Patent (such as customers in this District and 

throughout the United States) by, for example, selling, offering for sale, and encouraging 

customers to use and create infringing mesh network systems comprising access points.5

 

Moreover, Valtrus put AT&T on notice of its infringement of the ’892 Patent no later than on 

or about April 21, 2023. 

90. Defendants contribute to the direct infringement of at least claim 10 of the ’892 Patent under 

35 U.S.C. § 271(c) by supplying, with knowledge of the ’892 Patent, a material part of a 

5 See, e.g., https://www.att.com/support/smallbusiness/article/smb-internet/KM1320351/ (last 

visited September 26, 2023). 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 17 of 25 PageID #: 17
claimed invention, where the material part is not a staple article of commerce and is incapable 

of substantial noninfringing use. For example, the identified smart Wi-Fi extenders such as 

AT&T AirTies are a material part of the claimed invention, are not staple articles of commerce, 

and are incapable of substantial non-infringing uses. 

91. Defendants’ infringement has been willful in view of the above, and their failure to take any 

action, even after being put on notice, to stop their infringement or inducement of, or 

contribution to, infringement by others. 

EIGHTH CLAIM 

(Infringement of the ’155 Patent) 

92. Valtrus re-alleges and incorporates herein by reference paragraphs 1-91 of its Complaint. 

93. The ’155 Patent is generally directed to systems and methods for the management and control 

of interactive media sessions. 

94. Defendants have been on notice of the ’155 Patent and a specific factual basis for their 

infringement of the same since at least on or about September 25, 2023. On information and 

belief, Defendants have not taken any action to stop their infringement. 

95. Defendants have, under 35 U.S.C. 271(a), directly infringed, and continue to directly infringe, 

literally and/or under the doctrine of equivalents, one or more claims, including without 

limitation at least claim 1 of the ’155 Patent, by making, using, testing, selling, offering for 

sale, and/or importing hardware and/or software including components operable to implement 

an IMS (excluding any products licensed under the ’155 Patent). An exemplary claim chart 

concerning one way in which AT&T infringes claim 1 of the ’155 Patent is attached as Exhibit 

18. 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 18 of 25 PageID #: 18
96. Defendants also indirectly infringed, and continue to indirectly infringe, the ’155 Patent under 

35 U.S.C. § 271(b) and (c). 

97. Defendants knowingly and intentionally actively aid, abet, and induce others to directly 

infringe at least claim 1 of the ’155 Patent (such as customers in this District and throughout 

the United States) by, for example, selling, offering for sale, and encouraging customers to use 

hardware/software compatible with IMS. Moreover, Valtrus put Defendants on notice of their 

infringement of the ’155 Patent no later than on or about September 25, 2023. 

98. Defendants contribute to the direct infringement of at least claim 1 of the ’155 Patent under 35 

U.S.C. § 271(c) by supplying, with knowledge of the ’155 Patent, a material part of a claimed 

invention, where the material part is not a staple article of commerce and is incapable of 

substantial noninfringing use. For example, the identified components of the IMS (per the 

claim chart) are a material part of the claimed invention, are not a staple article of commerce, 

and are incapable of substantial non-infringing uses. 

99. Defendants’ infringement has been willful in view of the above, and their failure to take any 

action, even after being put on notice, to stop their infringement or inducement of, or 

contribution to, infringement by others. 

NINTH CLAIM 

(Infringement of the ’539 Patent) 

100. Valtrus re-alleges and incorporates herein by reference paragraphs 1-99 of its Complaint. 

101. The ’539 Patent is generally directed to computer architecture and techniques for 

controlling access to resources in a computer system. 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 19 of 25 PageID #: 19
102. Defendants have been on notice of the ’539 Patent and a specific factual basis for their 

infringement of the ’539 Patent since at least on or about September 25, 2023. On information 

and belief, Defendants have not taken any action to stop their infringement. 

103. Defendants have, under 35 U.S.C. § 271(a), directly infringed, and continue to directly 

infringe, literally and/or under the doctrine of equivalents, one or more claims, including 

without limitation at least claim 1 of the ’539 Patent, by making, using, testing, selling, offering 

for sale, and/or importing devices featuring a processor based on an ARM A-Profile 

architecture, such as ARMv8-A (excluding any products licensed under the ’539 Patent). 

104. For example, Defendants used and tested mobile devices, including the Google Pixel 6, 

that contain ARMv8-A based processors. An exemplary claim chart concerning one way in 

which Defendants have infringed claim 1 of the ’539 Patent is attached as Exhibit 19. 

105. Defendants also indirectly infringed, and continue to indirectly infringe, the ’539 Patent 

under 35 U.S.C. § 271(b) and (c). 

106. Defendants knowingly and intentionally actively aided, abetted, and induced others to 

directly infringe at least claim 1 of the ’539 Patent (such as customers in this District and 

throughout the United States) by, for example, selling, offering for sale, and encouraging 

customers to use mobile devices with infringing chips. Moreover, Valtrus put Defendants on 

notice of their infringement of the ’539 Patent no later than on or about September 25, 2023. 

107. Defendants contributed to the direct infringement of at least claim 1 of the ’539 Patent 

under 35 U.S.C. § 271(c) by supplying, with knowledge of the ’539 Patent, a material part of 

a claimed invention, where the material part is not a staple article of commerce and is incapable 

of substantial noninfringing use. For example, the identified ARM A-profile based processors 

(per the claim chart) are a material part of the claimed invention, are not a staple article of 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 20 of 25 PageID #: 20
commerce, and are incapable of substantial non-infringing uses. Additionally, Defendants sold 

mobile devices, including those noted above, that contain ARM A-profile based processors, 

which, when used, form a material part of the invention, where the material part is not a staple 

article of commerce and is incapable of substantial non-infringing use. 

108. Defendants’ infringement has been willful in view of the above, and their failure to take 

any action, even after being put on notice, to stop their infringement or inducement of, or 

contribution to, infringement by others. 

TENTH CLAIM 

(Infringement of the ’364 Patent) 

109. Valtrus re-alleges and incorporates herein by reference paragraphs 1-108 of its Complaint. 

110. The ’364 Patent is generally directed to an advanced conference call system. 

111. Defendants have been on notice of the ’364 Patent and a specific factual basis for their 

infringement of the ’364 Patent since at least on or about January 5, 2022. On information and 

belief, Defendants did not take any action to stop their infringement. 

112. Defendants have, under 35 U.S.C. § 271(a), directly infringed, literally and/or under the 

doctrine of equivalents, one or more claims, including without limitation at least claim 1 of the 

’364 Patent, by making, using, testing, selling, offering for sale, and/or importing their 

implementations of a conference call telephone system (excluding any products licensed under 

the ’364 Patent). 

113. For example, Defendants have provided a conference call telephone system. An exemplary 

claim chart concerning one way in which Defendants have infringed claim 1 of the ’364 Patent 

is attached as Exhibit 20. 

114. Defendants also indirectly infringed the ’364 Patent under 35 U.S.C. § 271(b) and (c). 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 21 of 25 PageID #: 21
115. Defendants knowingly and intentionally actively aided, abetted, and induced others to 

directly infringe at least claim 1 of the ’364 Patent (such as customers in this District and 

throughout the United States) by, for example, selling, offering for sale, and encouraging 

customers to use conference call telephone systems. Moreover, Valtrus put Defendants on 

notice of their infringement of the ’364 Patent no later than on or about January 5, 2022. 

116. Defendants’ infringement has been willful in view of the above and their failure to take any 

action, even after being put on notice, to stop their infringement or inducement of infringement 

by others. 

PRAYER FOR RELIEF 

WHEREFORE, Valtrus prays for judgment against AT&T as follows: 

A. That AT&T has infringed each of the Asserted Patents, and unless enjoined, will continue 

to infringe one or more of the Asserted Patents; 

B. That AT&T’s infringement of one or more of the Asserted Patents has been willful; 

C. That AT&T pay Valtrus damages adequate to compensate Valtrus for AT&T’s past 

infringement of each of the Asserted Patents, and present and future infringement of 

applicable Asserted Patents, together with interest and costs under 35 U.S.C. § 284; 

D. That AT&T pay prejudgment and post-judgment interest on the damages assessed; 

E. That AT&T pay Valtrus enhanced damages pursuant to 35 U.S.C. § 284; 

F. That AT&T pay be enjoined from infringing applicable Asserted Patents, or if its 

infringement is not enjoined, that AT&T be ordered to pay ongoing royalties to Valtrus for 

any post-judgment infringement of the Asserted Patents; 

G. That this is an exceptional case under 35 U.S.C. § 285; and that AT&T pay Valtrus’s 

attorneys’ fees and costs in this action; and 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 22 of 25 PageID #: 22
H. That Valtrus be awarded such other and further relief, including equitable relief, as this 

Court deems just and proper. 

DEMAND FOR JURY TRIAL 

Pursuant to Federal Rule of Civil Procedure 38(b), Valtrus hereby demands a trial by jury on all 

issues triable to a jury. 

Respectfully submitted, 

/s/ Matthew G. Berkowitz by permission Claire 

Henry 

Matthew G. Berkowitz – LEAD ATTORNEY 

Patrick R. Colsher 

Aaron L. Morris 

Reichman Jorgensen Lehman & Feldberg LLP 

100 Marine Parkway, Suite 300 

Redwood Shores, CA 94065 

Tel: (650) 623-1401 

mberkowitz@reichmanjorgensen.com 

pcolsher@reichmanjorgensen.com 

amorris@reichmanjorgensen.com 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 23 of 25 PageID #: 23
Khue V. Hoang 

Reichman Jorgensen Lehman & Feldberg LLP 

400 Madison Avenue, Suite 14D 

New York, NY 10017 

Tel: (212) 381-1965 

khoang@reichmanjorgensen.com 

Of Counsel: 

Andrea L. Fair 

Texas Bar No. 24078488 

Claire Abernathy Henry 

Texas State Bar No. 24053063 

WARD, SMITH & HILL, PLLC 

1507 Bill Owens Pkwy. 

Longview, TX 75604 

Tel: (903) 757-6400 

andrea@wsfirm.com 

claire@wsfirm.com 

Attorneys for Plaintiff 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 24 of 25 PageID #: 24
CERTIFICATE OF SERVICE 

I hereby certify that a copy of the foregoing document was filed electronically in 

compliance with Local Rule CV-5(a). Therefore, this document was served on all counsel who are 

deemed to have consented to electronic service on this 27 day of September, 2023. 

/s/ Claire Henry 

 Claire Henry 

Case 2:23-cv-00443-JRG Document 1 Filed 09/27/23 Page 25 of 25 PageID #: 25