Case 1:13-e*r-OU·€>§·2—L`Y“ téozzornent it-3 Fiteci G5il2fl3 Page- 5 ct 15 innovative Wireless Solutions, LLC 555 Republic Drive, Suite 2Utl • Plano, Texas $*5074 April IO. 2013 VLA CERTITHED MAIL TRACKWQ NUJBEV! Re; lnltingemein of Innovative Wireless Solutions, I..LC`s U.S. Patent Nos. 5,912,395, c.327,2c4 and 6,587,473 Dear Sir or I\·1a¢;lam: l am writing on behalf ol` Innovative Wireless Solutions. LLC ("IWS"). IWS is the assignee ot` all right, title, and interest in U.S. Patent 5,912,895 (the "‘895 Patent"}, 6,327,26¤l [the *264 Paten1"_}, 6,587,473 (the "‘473 Patent`) (collectively "ihe IWS Patent?). The IWS Patents generally relate to a wireless access point ("\·VAl"’) that connects to an Ethernet network. IWS has learned that_("your cnn·ipany’°} is inttinging one or more claims ot each of the DVS Patents by niakiiig, using, ol`te1rin,g to sell, and selling the use of am. llfililfi Sl'J2.l l wireless network (commonly referred to as a "Wil·i networlc”} that includes El wireless access point connected to an Ethernet network {collectively "·wirelcss Internet access" and/or "the inliinging services nnd produ:;ts°’). For example, your coiaipany is inningiug at least claim 40 of the ‘¢l=?3 Patent by performing each ol` the steps of that claim in at least the tollowing manner: 21} The WAP in your WiFi network provides eonnzoirnjcation between a CSMA/CD network (an Ethernet network) and a bidirectional coiiunuiiicatioiis path (an SO2.] l wireless network). b) The WAP includes an Ethernet interface that contains an Etl1€['1`l€lIllOdCll"I that receives lIlli)IlIlB.l,lU1ll)ZlCl§€`lS from an Ethernet network. cl} The WAP transnaits the infonnation packets over the 802. l. l wireless path in a clireetloii towards a mobile station. cl) The WAP includes a controller that implements the medium access control (‘*MAC") protocol as dctined in llilili 8t§2.`t 1. In accordance with the MAC protocol, the controller provides information that controls when wireless devices connected to the network are allowed to transmit, thereby causiiig the communications over the wireless network to occur in nl1alf·dt1ple>i1r12x1iner. The WAP receives inliirmnlion con·esponding_ to irifrirmatirin packets tiom the SO2,] l wireless path at the Ethernet modem and trzinsizrits those infoimatioii packets over the Etlicmet network. Similarly, your company is infringing at least claim 5 ol` the `264 Patent by operating at WAP that includes all clainietl elements in at least the tollowing manner: Case 1.:13—cv—Q04Q2—t..Y Document 1-3 Filed OG/12/13 Page 5 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 Ethernet 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 thc wirclcss network. t) The WAP includes a second buffer that holds frames received from the wireless network via the 802.1 1 interface and then supplies those frames via the Ethernet interface to the Ethernet network. Furthermore, your company is infringing at least claim 48 of the ‘895 Patent by making a wireless network that includes all claimed elements in at least the following manner: 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 Ethemet network. Ethemet is a CSMA/CD technology. The WAP incudes a buffer for buffering information packets received from the Ethemet network via the Ethemet interface for supply to the 802.11 wireless path. The WAP also includes a buffer for buffering information packets received from the 802.1 1 wireless path for supply to the Ethernet network via the Ethemet interface. The WAP also includes a controller that implements the meditun 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 802.1 1 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 be communicated bi—directional1y over the 802.11 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 Intemet 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. Czassss 2.:L§3-<;~1~£30¢l§3?Z~l..*r' D¤<;w‘¤w:z‘at 1-3 Fiéeeci G§fi2_."13 Wage: 7 mf 1}.5 M::1naa_s;cr April IO. 20] 3 Page 3 Additionally, your c0mpa.ny`s provision ufwirckc Iutcm·:L access 10i}1c:sc guests, customers, and cud users contributes to infri11g<:mc11i of thc: DVS Pmcms by those cutitics because your Witc{»‘:Ss network constitutes a anatcrial pam ofthe invention, was especially made or especially adapted. for usc in em iniiingcmczni ofthe [WS Patents, amd has min Sl1l]5{LIll€iEl] HOI1··iI3.H’iI1gil]g uses. ln pa1rtic·11!z1r, your wireless network constitutes a matcxiai pam uf thc claimed ixwcmtiun at lcast because it contains the Compcmcnts thai intcrflxtcb yOu? wirclcss uciwcrk to an Ethemet uctwmrk and provide control ir1f`0r1Tuxli0n to the wireless devices as claimed in Lhc IW S Patents. Your wireless nctwozk was made ur cSDr:ciz—1l15·’ adapted for usc in an ini·img,¢u1c11t of thc IWS Patents md has no subsmmial um;-imfring_i¤g uses at least because it coumins componams whose only purpose is to intcriaca your wireless network tm am Fihezmat network and tm pm vida: control iuiiarnmiion to the wireless devices as claimed in the IW Patcms. As a result 0f ymxr cmnpmfs iHh`i1`lgCI]lCHI 0ft]1cIWS Patents, IWS has suffered danmgcs and will continue to sui¥i:1· danmgcs in the futurr:. Accordingly, please ccnmct IW atmmey, I 1. as soon as possible tu discuss am appropriate resolution of`ym.u· c0mpa11y’s past and ongoing infringement ofthe DVS Patents. _ may be 1‘&€:ch€d as follows: Fznmcy Daniels PC 800 S. Austin Ave, Suite 20O (hzorgvstuwn, T cxas 78626 'l`ha¤,k you in advance for yuur attention tu this i1¤p0m1m1.m2».ttcr. Very truly yours, h1nc1¤:a¥iv·‘ 'irulcss Sululiupax, ,l`,.LC J · "‘“’ Pnui Heath