Case 1:13-e*r-00·€>§·2—L`Y“ Qoeonaent .t-3 Filed 05il2fZl3 Page- of 15 Innovative Wireless Solutions, LLC 555 Republic Drive, Suite 200 ¤ Plano, Texas 75074- April lll, 2UlS VIA CERTIFIED MAIL 'YRAMNG NUMEER Re; lllil`ll'}g©ll'1C.l]l of Innovative W i relcss Solutions, Ll..C’s U.S. Pzttent Nos. 5,912,895, 6,327,264 and 6,587,473 Deer Sir or Mztdzun: l ain writing on behalt`twt`ln11ov*etive \\·'ireless Solutions, LLC ("l\’~iS"). {WS is the assignee ol` all right, title, and interest in U Patent Nos. 5,9l2,895 (the "‘895 Patcirf`), 6,327,264 {the "‘264 Pa1tent’ ’), 6,587,473 (the `“`473 Patent") (collectively “the DNS Patertis"). The IWS Patents generally relate to a wireless ziccess point ("\·\#'AP") that connects to am Ethernet network. EWS has lczuned tl:ie (‘“y0ur con;ipany"} is infringing one or more claims of each ofthe lWS Patents by m21l·:ing, using, offering to sell, and selling the use ofan USER 802. l. l, wireless network (comm only referred to as at "Wi1‘i network") that inc,|.udes at wireless access point connector? Lo an Etherrict network (icollcctively "wircless lntcrnct access" anntlfior "thc inhinging services and products“). For example, your ctompatriy is itrfringing at least cleiin 40 ofthe ‘473· Patent by performing each ol` the steps ol that claim in ot least the following mzts.i.ner: 3) The WAP in }l(tllt` Wilii network provides comrznioicstion between s CSl\·iA.*'(1l) nctworls. (am Ethernet 1`1€$l.-WOl.`l€) and at bielirectioxml conurnuiicaitions patll (ari 802.l l wireless network}. h) The WAP iricliides an litl1,ernctinteri’:.tce that contains an Ethernet modem that receives infomration packets from am Ethernet networl:. cl) The WAP transmits the inlonnotion pockets over the 802.11 wireless prith in a direction towards at mobile station. di) The W./\.l’ includes zi controller that implements the mecliurn access control ("l\#‘lACf"} protocol as defined in IEEE 802.11. ln ziccordmice 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 oc-cur in 21 ltilltiditple-x 1'1l€l.t1l`l€l’, e) The XVAP receives information corresponding to inlbrrnzition pzrclaets liorn the 802.l l wireless path att the lltlrcrncl. modem and transmits those inlormation packets over the litlrcmct network. Sl]}"lll€Il`l;\’, your company is inlringiug et least claim 5 ofthe 2264 Patent by npemtlirg as WAP that includes all clniiuetl elements in at least thc following mztnneri Case 1:13—cv—O0492—L.Y Document 1-3 Filed CJQE/12/1.3 Page 10 of 1.5 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 ha.1f—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. fj 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 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 Ethernet interface to an Ethemet network. Ethemet 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 infomation 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 medium access control ("MAC") protocol as defined in IEEE 802.11. c) A wireless station is connected at a second end of the 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 infonnation packets to be communicated bi—directiona11y 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 lntemet access, advertising that wireless Intemet 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 Internet access constitutes direct infringement of the IWS Patents. {Iago 11:13-{rxr-GO4Q2~§.`f E3o<;am‘aeam L3 Filed G£:Ei'fl.I§Ef}.3 3.1. of 1.5 Manager April 10, 2013 Pago 3 Adnlilio11z1lly, your compemyki provision of wireless loicriwol. uccoss to those guests, c-ust,om<:rs, and cud uscrs coutyibulcs to iofringcmcnl of thc 1W S I’c1tcuis by those Cl1ti`llCS bocauso yo uz wirclcss network coustitutcs o material part of thc im-*<:utio11, was especially maclc or especially adapted for use in ami11frii1gc111c311.t<J,l?1lJe: IWS Patents, and has no substantial mm-i.nhingii1g uses. ln pamicular, your wiyclcss rictxvork constitutes a mzxtcrial pam ofthe: claimed invention ant least because it contains the components that interface your wlzcloss 11ctw0rl~; to an Etl1<:111c’E network and provide: control i11iom1a tion to thc-! wireless devices as cluimccl in thc IWS Paicms. Your wireless network was made or especially adoptcd for usc. in on i11fring¤:m<t11I0f`th¤: IWS Patents and has no Substantial noll-iohingirlg, uses at least because it contains components whose only pmposc is to iulcrfhoc you: wireless network to an Ethemct uciwoiik and to provide control information to thc wireless devices as claimed iu the YWH Pzucawa. As a result of your <;.ompuuy’s ll‘tli'i.llgCiHCI1T ofthe IWS Patents, IWS has suffered clmnagcs and will continue to sullér dmtnagcs in the future. ,/\cco1·di1·zgly, please comaict IWS`s oltomey, I 1, as soon aw possible to discuss an zappro·pr%a,t¢: rcsolluion of your comp:1ny’s pam and ongoing ll'lfl'l11gCI'[l€£l`lZ of the IWS Patents. - may bc roaclwd as follows: Furucy [Juuicls PC 800 S. Austin Ave, Suite 200 Georgetown, '1`cxus 78626 "1`hamk you in ar.lvzm<;e for your attcmtion to ihis irnportum matter, Very truly yours, lo1zovativ — I ;i1=a:,lcss Solutiooso LLC _ . uns-""" ' i Pool Hooth