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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF WISCONSIN


GLOBAL WIRELESS SOLUTIONS LLC,


Plaintiff,

v. Case No. 2:14-cv-00496

J URY TRIAL DEMANDED
MOBI WIRELESS MANAGEMENT, LLC,


Defendant.


COMPLAINT FOR PATENT INFRINGEMENT


Plaintiff, Global Wireless Solutions LLC, for its Complaint against MOBI Wireless
Management, LLC, alleges as follows:
THE PARTIES
1. Plaintiff, Global Wireless Solutions LLC (Global Wireless) is a Wisconsin
limited liability company with its principal place of business located in New Berlin, Wisconsin.
2. Defendant, MOBI Wireless Management, LLC (MOBI) is an Indiana limited
liability company with its principal place of business located in Indianapolis, Indiana.
JURISIDCTION AND VENUE
3. This is an action for patent infringement arising under Title 35 U.S.C. 1 et seq.,
of the United States.
4. This Court has subject matter jurisdiction pursuant to 28 U.S.C. 1331 (federal
question), 1332(a) (diversity of citizenship), and 1338(a) (question related to patents).
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5. This Court has specific personal jurisdiction over MOBI because, upon
information and belief, MOBI has used, sold and/or offered to sell the claimed technology in
this District or in furtherance of its business interests with direct ties to this District. Moreover,
this Court has general personal jurisdiction over MOBI because, upon information and belief, it
conducts regular and systematic business in this District.
6. Venue is proper in this judicial district pursuant to 28 U.S.C. 1391 and 1400.
FACTS GIVING RISE TO PATENT INFRINGEMENT

7. On J anuary 1, 2013, the United States Patent and Trademark Office duly and
legally issued United States Patent No. 8,346,212 (the 212 Patent) entitled Resource And
Utilization Management Of Telecommunication Devices. A true and correct copy of the 212
Patent is attached as Exhibit A.
8. Global Wireless is the assignee and sole owner of the 212 Patent.
9. The 212 Patent discloses an invention for providing methods and systems for
resource planning and utilization management of telecommunications devices within an
organization. The 212 Patent technology manages common service providers in a centralized
location allowing for advanced reporting, pooling and cost allocation resulting in reduced
telecommunications and wireless expenses.
10. Global Wireless has been conducting business using the 212 Patent technology
in furtherance of its business enterprise.
11. Defendant MOBI is a competitor of Global Wireless and has been using the 212
Patent technology and thus infringing the 212 Patent pursuant to 35 U.S.C. 271(a).
12. MOBI has been aware of the 212 patent and despite such knowledge continues
to infringe the 212 patent.
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WHEREFORE, Global Wireless prays that a judgment be entered in its favor and against

MOBI as follows:

(a) MOBI be found to infringe the 212 Patent under 35 U.S.C. 271;
(b) Global Wireless be awarded damages pursuant to 35 U.S.C. 284;
(c) MOBIs infringement be found to be willful, and thus, damages be
trebled pursuant to 35 U.S.C. 284;
(d) Global Wireless be awarded its attorney fees pursuant to 35 U.S.C. 285;
(e) Global Wireless be awarded prejudgment interest; and
(f) any further and just relief the Court deems equitable and appropriate.

Date: April 30, 2014 Respectfully submitted,

GLOBAL WIRELESS SOLUTIONS LLC

By: /s/ Mark M. Grossman_____
Mark M. Grossman #6208323
mgrossman@grossmanlegal.com
Nicholas J .R. Spear #6307064
nspeare@grossmanlegal.com
Kyle D. Wallenberg #6314218
kwallenberg@grossmanlegal.com
Grossman Law Offices
309 W. Washington St., Suite 700
Chicago, IL 60606
Phone: (312) 621-9000









































EXHIBIT A