{ieee 5l.:Li3-<;~1~t30¢l§l?Z~l..*r' lZ>or;tlmet‘at 3.-3 Filed tltifl 2.*13 Page il. of jl.5 Innovative Wireless Solutions, LLC 555 Republic Drive, Suite 200 ¤ Plano, Texans 75G7»l· April 10,, 2013 VIA CERTIFIED MAIL TRAGKINGNUMSEI 1 eeee it eeeee Re: Infringement ollnnovative Wireless Solutions, LLC`s U.S. Patent Nos. 5,912,895, 6,327,264 and 6,5S‘7,<l73 Dear Sir or Mauktttt: 1 inn writing on hehalftwt`Innox·e1tive Wireless Solutions. LLC ("l\VS"). IWS is the assignee of all right. title, and interest in l..l.S. Potent Nos. 5,912.895 (the "`S95 Patent"), 6,327,264 (the "‘264 Patent"). 6,58?',473 (the "‘=l73 Patent") (collectively "the IWS Patents"fl, The IWS Patents generally relate to st wireless access point (“WAP"`) that connects to an Ethernet. network. 1WS has leztnted lluii-("yonr contpeng,-”’} is lnfringlrtg one or more claims of each ofthe IWS Patents by iitakiiig, using, offering to sell, and selling the use oian IEEE 802.1 l wireless network (commonly referred to at ‘“WiFi networl<") that includes tt wireless access point connectecl to an Ethernet network (collectively °`Wireless lttternet :1ccess” mid/or "tlte in.lrin.ging services and products?. For example, your eontpnny is infringing nt. least claim 40 of the ‘=l73 Patent by performing eat:-h ol` the steps of that claim in at least the following manner: zi) The WAP in your `Wil`i network provides com.munii>zilion between at CSl‘·.*l/WC1) network inn Ethernet network) and at ibidirecttonal cont.tnt1t1ic-ations path {an Stl2.ll wireless network). lil) The- WAP includes an lithernet interface that conlztins on lithemet modem that receives inforntetit>ti·pz1c.kets {worn an Ethernet network. c) The WAP trztnsrnits the information pzu:-lccts over the 802.1 l wireless pztth in a direction towards at mobile station. rl) The \ll#'AP includes at eonttoller that iittploments the medium access eonuol ("MACT") protocol M defined in IEEE 802.1 l. In accordance with the MAC protocol, the controller provides information that controls when wireless devices connected to the network are allowed to transrrnt, thereby causing the eomrnnnieattons over the wireless network to occur in at ltztlf-duplex 11131Cl11£`l'. el The WAP receives intortnation corresponding; to information packets from the 302.11 wireless path at the Ethernet tnodent and trmtsntits those irtfnrntetion pcacltets over the l`;llQl’lGl`.ll{Zl. network. Similztrly, your company is infringing at least claim 5 ol`the *264 Potent hy operating ti W`.=\iP that includes all clniined elements in at letrst the lollowittg ntémttort Case 1.:13—cv—Q0¤.Q2—E..Y Document 1-3 Filed OG/12/13 Page 2 ot 15 Manager April 10, 2013 Page 2 a) The WAP in your WiFi network allows wireless devices to connect to a network. b) The WAP includes an Ethemet interface for coupling to an Ethernet network. Ethernet is a CSMA/CD technology. c) The WAP includes an 802.11 interface for coupling to the 802.11 wireless network which provides a wireless bidirectional communications path. d) The WAP includes a controller that implements the medium access control ("MAC") protocol as defined in IEEE 802.11. In accordance with the MAC protocol, the controller provides information that controls when wireless devices connected to the network are allowed to transmit, thereby causing the communications over the wireless network to occur in a half—duplex manner. e) The WAP includes a first buffer that holds frames received from the Ethernet network via the Ethernet interface and then supplies those frames via the 802.11 interface to the wireless network. f) The WAP includes a second buffer that holds frames received from the wireless network via the 802.11 interface and then supplies those frames via the Ethernet interface to the Ethernet network. Furthermore, your company is infringing at least claim 48 ofthe ‘895 Patent by making a wireless network that includes all claimed elements in at least the following marmer: a) The WAP in your WiFi network provides communication with a CSMA/CD network (an Ethernet network) via a bidirectional communications path (an 802.11 wireless path). b) The WAP is located at a first end of the 802.11 wireless path and includes an Ethemet interface to an Ethernet network. Ethernet is a CSMA/ CD technology. The WAP incudes a buffer for buffering information packets received from the Ethernet network via the Ethernet interface for supply to the 802.11 wireless path. The WAP also includes a buffer for buffering information packets received from the 802.11 wireless path for supply to the Ethernet network via the Ethernet interface. The WAP also includes a controller that implements the medium access control ("MAC") protocol as defined in IEEE 802.11. c) A wireless station is connected at a second end ofthe 802.11 wireless path. The wireless station includes a buffer for buffering information packets received from the 802.11 wireless path, a buffer for buffering information packets to be supplied to the 802.11 wireless path, and a MAC controller. d) The MAC controller in the WAP and the MAC controller in the wireless station are arranged to exchange control information over the 802.11 wireless path so as to allow information packets to bc communicated bi-directionally over the 802.1 1 wireless path between the buffers of the WAP and the wireless station in a half-duplex manner. In addition to directly infringing the IWS Patents, your company is also inducing others to infringe the IWS Patents by offering wireless Internet access, advertising that wireless Internet access, and encouraging others to use that wireless Internet access. These other entities include your company’s guests, customers, and end users, whose connection of their wireless devices to your network and use of the wireless Intemet access constitutes direct infringement ofthe IWS Patents. Casts 2.:Li3-<;~1~£30¢l§3?Z~l..*r' D¤<;w‘¤w:z‘at 1-3 Fiéeeci G§fi2_."13 Wage: 3 mf 1}.5 Nlmaagcr April 10, 2013 Page 3 Additionally, your c01a1p;my’s provision of wireless lmrarinezi access tm these: guests, cust,u1m:rs, and and users cmitribulcs LD ll'}f“l'll]gB3’Il€'t’ll. 0l`1i1r: IW S Patents by those entities because your wireless network constitutes El material part ofthe invention. was especially made ox especially adapted for use in an infiingcmem: mflhc: [WS Patents, and has nm substantial nu¤—i1·u°i·iuging uses. In }3EiTl.iLI·Lll(·J.1`, your wireless network constitutes at malaria.? part ufthc claimed invcminm at least because: it contains thc components that iutcrthcc your wireless network t0 em Ethernet tzctwcrk amd prm-‘icI·& control i11f01‘mati011 to lhc wireless devices claiinacl iu thc ,l`WS Patents. Your wireless mciwmrk was made: 01* especially adapted for usc in L15] ii`ll·l`l1'lg€Il'1€IlJ[ ofthe IWS Patents and has 110 substzxutieal 11011-i :1 iiriuging uses at least because it curtlajxls CG£I1[)OHB[llS whose only purpose is to intcrfmc your wirclcss 1xctw01‘1< IO an Etlmmct network and to provide ccmtml inlbmmtiun tu thc: wireless devices as clzaimcd in thc FWS Patents. As at rcsult 0f your cmtipunfs .llUcl`il’lgCIl'1E3I1T cf thc IWS Pzstemts, IWS has suffctcd damages and will continue un suffix: damages in thc future. Accordingly, please cunmct {WSE: attorney, _ 1, as soon as possible to discuss an appropriate resolution 4i>1E`yuur ctampamy’s past and ongoing infrixigcmszmt of the IWS Patents. _ may bc rczxchcd as follows: liztrnay Daniels PC 800 S. Austin Ave, Suite 200 Georgetown, 'lkrxets 78626 Tinznink you in zulvumcca xlhr your attcrntiuu to this iitxipuftant matter. Vcly truly yo urs. l1m0v:a,tiv‘· ’ira]·:ss Solutions, 1,-LC _ ...¤~····` ` "m` Paul Ham};