22-01-04 Estech v. BMW Complaint

Case 2:22-cv-00003-JRG-RSP Document 1 Filed 01/04/22 Page 1 of 22 PageID #: 1
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION
ESTECH SYSTEMS IP, LLC, CIVIL ACTION NO. 2:22-cv-00003
Plaintiffs, ORIGINAL COMPLAINT FOR

v. PATENT INFRINGEMENT
BAYERISCHE MOTOREN WERKE AG JURY TRIAL DEMANDED

and BMW OF NORTH AMERICA, LLC
Defendants.
ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff Estech Systems IP, LLC (“Estech” or “Plaintiff”) files this original complaint
against Bayerische Motoren Werke AG and BMW of North America, LLC (“BMW” or
“Defendants”) alleging, based on its own knowledge as to itself and its own actions, and based on
information and belief as to all other matters, as follows:
PARTIES
1. Estech Systems IP, LLC is a Texas corporation, with its principal place of business
at 3701 East Plano Parkway, Suite 300, Plano, Texas 75074.
2. Defendant Bayerische Motoren Werke AG is a corporation organized and existing
under the laws of Germany, with a place of business at Petuelring 130, D-80788, Munich,
Germany.
3. Defendant BMW of North America, LLC is a corporation organized and existing
under the laws of Delaware, with a place of business at 300 Chestnut Ridge Road, Woodcliff Lake,
NJ 07675. BMW may be served through its registered agent, CT Corporation System, a 1999
Bryan Street, Suite 900, Dallas, TX 75201-3136.

JURISDICTION AND VENUE
4. This is an action for infringement of United States patents arising under 35 U.S.C.
§§ 271, 281, and 284–85, among others. This Court has subject matter jurisdiction of the action
under 28 U.S.C. § 1331 and § 1338(a).
5. Venue is proper in this district pursuant to 28 U.S.C. §§ 1400(b) and 1391(b-c).
Defendant Bayerische Motoren Werke AG is a foreign corporation that may be sued in any federal
district with personal jurisdiction over it.
6. Defendant Bayerische Motoren Werke AG is subject to this Court’s specific
personal jurisdiction pursuant to principles of due process and FRCP 4(k)(2), the federal long-arm
statute, because (1) it has substantial contacts with the United States and has committed and/or
induced acts of patent infringement in the United States; and (2) it is not subject to jurisdiction in
any state’s courts of general jurisdiction. Upon information and belief, Defendant Bayerische
Motoren Werke AG receives a substantial portion of its revenue from customers located in the
United States, including from customers residing in the District.
7. Defendant Bayerische Motoren Werke AG is also subject to this Court’s specific
personal jurisdiction pursuant to the Texas Long Arm Statute, due at least to Defendant Bayerische
Motoren Werke AG’s substantial business in this forum, including (i) at least a portion of the
infringements alleged herein; and/or (ii) regularly doing or soliciting business, engaging in other
persistent courses of conduct, and/or deriving substantial revenue from goods and services
provided to individuals in Texas and in this district.
8. Defendants are subject to this Court’s specific and general personal jurisdiction due
at least to Defendants’ substantial business in this forum, including (i) at least a portion of the
infringements alleged herein; and/or (ii) regularly doing or soliciting business, engaging in other
2
persistent courses of conduct, and/or deriving substantial revenue from goods and services
provided to individuals in Texas and in this district.
9. Specifically, Defendants intend to and do business in Texas, directly or through
intermediaries and offer their products and/or services, including those accused herein of
infringement, to customers and potential customers located in Texas, including in the Northern
District of Texas.
10. Defendants maintain at least one regular and established places of business in this
district, including at 6800 Dallas Parkway, Plano, Texas 75024.
THE TECHNOLOGY
11. Estech is an affiliate of Estech System, Inc. (“ES Inc.,”) which for more than 30
years has been a leading U.S.-based provider of end-to-end business phone solutions. ES Inc.’s
Network Operations Center is located in Plano, Texas.
12. Since 1987, ES Inc. has sold more than 400,000 solutions to its customers, working
with more than 1,500 certified partners nationwide. Its customers include small and large
businesses across the country.
13. Recognizing that business doesn’t get done without communication, ES Inc.
provides powerful products that that are easy and simple to use. ES Inc.’s products are engineered
to make intelligent technology that is intuitive and user-friendly, empowers employee productivity,
and fuels customer satisfaction.
14. ES Inc.’s technology is American-engineered. From its Plano, Texas headquarters,
ES Inc. provides a full solutions portfolio of modern business phone systems, including Cloud,
Hybrid, Pure IP, and SIP dial tone products. Given ES Inc.’s end-to-end product offerings, its
customers are empowered to choose the product features they need and want.
3
15. ES Inc.’s products include the most integrated cloud PBX in the market—the
award-winning ESI Cloud PBX; Voice over IP (VoIP) products and systems; and on-premises
products. A cloud-based PBX is a sophisticated telephone exchange system that uses a cloud
infrastructure to provide communication services, such as telephony services.
16. VoIP transmits and receives voice communications over data networks, such as the
Internet or private networks, using the Internet Protocol (IP).
17. VoIP systems offer several advantages over traditional phone systems including,
but not limited to, lower cost and more efficient network management.
18. VoIP systems also allow enable integration of additional communication services.
19. ES Inc. cloud-based VoIP products have handled billions of call minutes.
20. ES Inc. also provides U.S.-based, best-in-class technical support for its customers.
21. The patents-in-suit, U.S. Patent Nos. 8,391,298 (the “’298 patent”), 7,068,684 (the
“’684 patent”), 6,067,349 (the “’349 patent”), and 7,123,699 (the “’699 patent”) (collectively, the
“Estech Asserted Patents”), are generally directed to systems and methods for providing robust,
feature-rich communications systems including, but not limited to, VoIP telephony and additional
communication services that can be integrated with a VoIP telephony system.
COUNT I
Infringement of U.S. Patent No. 8,391,298
22. Estech repeats and re-alleges the allegations in Paragraphs 1-21 as though fully set
forth in their entirety.
23. Estech owns all substantial rights, interest, and title in and to the ’298 patent,
including the sole and exclusive right to prosecute this action and enforce the ’298 patent against
infringers, and to collect damages for all relevant times. The United States Patent and Trademark
4
Office duly issued the ’298 patent on March 5, 2013. A copy of the ’298 patent is attached as
Exhibit A.
24. The ’298 patent is titled “Phone Directory in a Voice Over IP Telephone System.”
The ’298 patent describes information processing systems that store a list of phone numbers,
integrated with a VoIP telephony system, to provide those phone numbers to the user of a VoIP
telephone. The user can use that list to dial the telephone number of another user associated with
the VoIP telephony system.
25. The claims of the ’298 patent are not directed to an abstract idea. For example,
claim 1 of the ’298 patent recites a specific arrangement of devices and networking components.
Together those devices and networking components enable a user of a first telecommunications
device to observe a list of a plurality of telecommunications extensions. The list of extensions is
stored in a server within a specific networking configuration, and the user can select to view a
subset of the extensions. Taken as a whole, the claimed inventions of the ’298 patent are not
limited to well-understood, routine, or conventional activity. Rather, the claimed inventions
include inventive components that improve upon the functioning and operation of information
processing systems.
26. The written description of the ’298 patent describes in technical detail each of the
limitations of the claims, allowing a skilled artisan to understand the scope of the claims and how
the non-conventional and non-generic combination of claim limitations is patently distinct from
and improved upon what may have been considered conventional or generic in the art at the time
of the invention.
27. Defendants infringed the ’298 patent by making, having made, using, importing,
providing, supplying, distributing, selling, or offering for sale products and/or systems, including
5
VoIP telephone systems and networking equipment utilized by Defendants (“Accused
Instrumentalities”).
28. The Accused Instrumentalities provide VoIP-based voice calling and data-
networking services to VoIP telephony devices.
29. The Accused Instrumentalities use first, second, and third LANs that are coupled
with a WAN.
30. The Accused Instrumentalities include VoIP telephony devices connected to LANs,
the VoIP telephony devices having telecommunications extensions associated therewith, the
telecommunications extensions being coupled to the second and third LANs.
31. The VoIP telephony devices include circuitry (i) enabling users of VoIP telephony
devices to observe a list of telecommunications extensions; (ii) to automatically call one of the
telecommunications extensions in response to a user selecting one of the telecommunications
extensions from the list; and (iii) enabling the use to select between observing the list of
telecommunications extensions coupled to the second LAN or the third LAN.
32. The Accused Instrumentalities include servers in the second LAN that store
telecommunications extensions accessed across the WAN.
33. As described above, Defendants directly infringed (literally or under the doctrine
of equivalents) at least Claim 1 of the ’298 patent. Defendants’ infringement in this regard is
ongoing.
34. Estech has been damaged as a result of the infringing conduct by Defendants
alleged above. Thus, Defendants are liable to Estech in an amount that compensates it for such
infringements, which by law cannot be less than a reasonable royalty, together with interest and
costs as fixed by this Court under 35 U.S.C. § 284.
6
35. Estech or its predecessors-in-interest have satisfied all statutory obligations
required to collect pre-filing damages for the full period allowed by law for infringement of the
’298 patent.
36. Defendants also indirectly infringed the ’298 patent by inducing others to directly
infringe the ’298 patent. Defendants induced end-users, including Defendants’ customers,
partners, personnel, clients, and contractors, to directly infringe (literally or under the doctrine of
equivalents) the ’298 patent by making and using the Accused Instrumentalities. Defendants took
active steps, directly or through contractual relationships with others, with the specific intent to
cause them to use the Accused Instrumentalities in a manner that infringes one or more claims of
the ’298 patent, including, for example, Claim 1 of the ’298 patent. Such steps by Defendants
included, among other things, advising or directing customers, partners, personnel, contractors or
end-users to make or use the Accused Instrumentalities in an infringing manner; advertising and
promoting the use of the Accused Instrumentalities in an infringing manner; or distributing
instructions that guide users to use the Accused Instrumentalities in an infringing manner.
Defendants are performing these steps, which constitute induced infringement with the knowledge
of the ’298 patent and with the knowledge that the induced acts constitute infringement.
Defendants are aware that the normal and customary use of the Accused Instrumentalities by others
would infringe the ’298 patent. Defendants’ inducement is ongoing.
37. Defendants also indirectly infringed by contributing to the infringement of the ’298
patent. Defendants contributed to the direct infringement of the ’298 patent by its customers,
partners, personnel, contractors, clients, and suppliers. The Accused Instrumentalities have special
features that are specially designed to be used in an infringing way and that have no substantial
uses other than ones that infringe one or more claims of the ’298 patent, including, for example,
7
Claim 1 of the ’298 patent. The special features include, for example, the devices and networking
components recited in Claim 1, including the interrelation between those devices and networking
components, that allow the claimed server to provide a list of extensions and for the user to select
to view a subset of the extensions. The special features constitute a material part of the invention
of one or more of the claims of the ’298 patent and are not staple articles of commerce suitable for
substantial non-infringing use. Defendants’ contributory infringement is ongoing.
38. On information and belief, Defendants had knowledge of the ’298 patent at least as
of the date when they were notified of the filing of this action.
39. Furthermore, on information and belief, Defendants have a policy or practice of not
reviewing the patents of others (including instructing its employees to not review the patents of
others), and thus has been willfully blind of Estech’s patent rights.
40. Defendants’ actions are at least objectively reckless as to the risk of infringing a
valid patent and this objective risk was either known or should have been known by Defendants.
41. Defendants’ direct and indirect infringement of the ’298 patent is, has been, and
continues to be willful, intentional, deliberate, or in conscious disregard of Estech’s rights under
the patent.
43. Estech has suffered irreparable harm, through its loss of market share and goodwill,
for which there is no adequate remedy at law. Estech has and will continue to suffer this harm by
virtue of Defendants’ infringement of the ’298 patent. Defendants’ actions have interfered with
8
and will interfere with Estech’s ability to license technology. The balance of hardships favors
Estech’s ability to commercialize its own ideas and technology. The public interest in allowing
Estech to enforce its right to exclude outweighs other public interests, which supports injunctive
relief in this case.
COUNT II
Office duly issued the ’684 patent on June 27, 2006. A copy of the ’684 patent is attached as
Exhibit B.
46. The ’684 patent is titled “Quality of Service in a Voice Over IP Telephone System.”
The ’684 patent describes information handling systems used to transmit voice using VoIP
technology. The information handling systems throttle the amount of data being transferred from
a workstation connected to the VoIP telephone.
claim 36 of the ’684 patent recites specific steps performed by a specific arrangement of devices
and networking components and operations performed by those components. Together, those
devices and networking components provide quality of service to audio information by throttling
the amount of data being transferred through a VoIP telephony device. Taken as a whole, the
claimed inventions of the ’684 patent are not limited to well-understood, routine, or conventional
9
activity. Rather, the claimed inventions include inventive components that improve upon the
function and operation of information processing systems.
of the invention.
49. Defendants infringed the ’684 patent by making, having made using, importing,
providing, supplying, distributing, selling, or offering for sale products and/or systems, including
50. The Accused Instrumentalities provide VoIP-based voice calling and data-
networking services to VoIP telephony devices.
51. The Accused Instrumentalities include VoIP servers such that audio information
for VoIP-based voice calls is communicated between at least VoIP telephony devices and VoIP
servers.
52. The Accused Instrumentalities include workstations (including, but not limited to,
for example, desktop computers, workstations, laptops, embedded devices, point-of-sale devices,
and mobile devices) that send and receive data from data servers (including, but not limited to, for
example, websites) that transfer data through VoIP telephony devices.
53. The Accused Instrumentalities sufficiently throttle data sent from workstations to
VoIP telephony devices to increase a rate of transfer of audio information during the
communication of audio information, the data throttling comprises reducing a future amount of
10
data from being transferred from the workstation if the amount of data exceeds a predetermined
threshold.
ongoing.
alleged above. Thus, Defendants are liable to Estech in an amount that adequately compensates it
for such infringements, which by law cannot be less than a reasonable royalty, together with
interest and costs as fixed by this Court under 35 U.S.C. § 284.
’684 Patent.
11
partners, personnel, contractors, clients, and suppliers. The Accused Instrumentalities have special
components, that throttle the amount of data being transferred through the telephone. The special
features constitute a material part of the invention of one or more of the claims of the ’684 patent
and are not staple articles of commerce suitable for substantial non-infringing use. Defendants’
contributory infringement is ongoing.
59. On information and belief, Defendants have knowledge of the ’684 patent at least
as of the date when they were notified of the filing of this action.
12
the patent.
COUNT III
Office duly issued the ’699 patent on October 17, 2006. A copy of the ’699 patent is attached as
Exhibit C.
13
67. The ’699 patent is titled “Voice Mail in a Voice Over IP Telephone System.” The
’699 patent describes an information handling system for storing a voice mail message in a voice
mail box in a voice mail system within a first local area network (LAN). A user can access and
listen to the voice mail using a VoIP telecommunications system within a second LAN by
connecting to the first LAN via a wide-area network (WAN), such as the Internet.
claim 1 of the ’699 patent recites a specific arrangement of devices in a networking environment.
Together those devices enable a user within a second LAN to access and listen to voice mail
messages stored within a first LAN. Taken as a whole, the claimed inventions of the ’699 patent
are not limited to well-understood, routine, or conventional activity. Rather, the claimed
inventions include inventive components that improve upon the functioning and operation of
information processing systems.
of the invention.
70. Defendants infringed the ’699 patent by making, having made, using, importing,
providing, supplying, distributing, selling, or offering for sale products and/or systems including
71. The Accused Instrumentalities operate under a routable protocol including, but not
limited to, for example, TCP/IP or UDP/IP.
14
72. The Accused Instrumentalities include VoIP servers that store a voice mail message
in a voice mail box in a voice mail system within a first LAN.
73. The Accused Instrumentalities include VoIP telephony devices coupled to the
second LAN that provide a sensory indication when the voice message is stored in the voice mail
box within the first LAN. The VoIP telephony devices allow a user to access the voice mail system
within the first LAN to listen to the voice message stored in the voice mail box. The VoIP
telephony devices allow a user to access the voice mail message stored in the voice mail box
provided by the VoIP Servers by using communication protocols, including, but not limited to, for
example, TCP/IP, UDP/IP, Skinny Client Control Protocol (SCCP), Session Initiation Protocol
(SIP), MiNET protocol, Session Description Protocol (SDP), Real-time Transport Protocol (RTP),
and Real-time Transport Control Protocol (RTCP) protocols to: (i) establish a channel between
the first and second LANs over the WAN; (ii) couple an audio path over the channel between the
telecommunications device and the voice mail box; and (iii) stream voice data containing the voice
message from the voice mail box to the telecommunications device over the audio path.
74. The VoIP telephony devices and VoIP servers can establish a channel between the
first and second LANs over the WAN, wherein the establishing includes: (i) in response to an
input at VoIP telephony devices, sending a user mail box connection message from the second
LAN to the first LAN requesting a channel, wherein the user mail box connection message includes
an extension associated with VoIP telephony devices and an identification of the voice mail box;
(ii) assigning the channel by VoIP servers in the first LAN; and (iii) sending a connection
established message from VoIP servers in the first LAN to the second LAN.
15
ongoing.
’699 patent.
16
partners, personnel, contractors, and suppliers. The Accused Instrumentalities have special
components, that allow a user to access and listen to the voice mail using a VoIP
telecommunications system within a second LAN by connecting to the first LAN via a wide-area
network (WAN), such as the Internet. The special features constitute a material part of the
invention of one or more of the claims of the ’699 patent and are not staple articles of commerce
suitable for substantial non-infringing use. Defendants’ contributory infringement is ongoing.
17
the patent.
COUNT IV
Office duly issued the ’349 patent on May 23, 2000. A copy of the ’349 patent is attached as
Exhibit D.
18
88. The ’349 patent describes a telephone and voice mail system. When a calling party
calls a user of the system, the system receives the caller’s caller ID information and associates that
information with a voicemail message. By doing so, the recipient of the voicemail can
automatically call back the caller while listening to the voicemail message.
claim 1 of the ’349 patent recites specific steps performed on specific components of voice
communications. Taken as a whole, the claimed inventions of the ’349 patent are not limited to
well-understood, routine, or conventional activity. Rather, the claimed inventions include
inventive components that improve upon the function and operation of telephone and voice mail
systems.
of the invention.
91. Defendants made, have made, used, imported, provided, supplied, distributed, sold,
and offered for sale products and/or systems, including voice mail systems utilized by Defendants
(“Accused Instrumentalities”).
92. The Accused Instrumentalities include local area networks, VoIP devices such as
telephones, and voice mail infrastructure.
93. By doing so, Defendants have directly infringed (literally and/or under the doctrine
of equivalents) at least Claim 1 of the ’349 patent.
19
94. Defendants have infringed the ’349 patent by making, having made, using,
importing, providing, supplying, distributing, selling, or offering the Accused Instrumentalities for
sale.
98. Defendants’ direct infringement of the ’349 patent has been willful, intentional,
deliberate, or in conscious disregard of Estech’s rights under the patent.
100. Estech and/or its predecessors-in-interest have satisfied all statutory obligations
’349 Patent.
JURY DEMAND
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Estech requests a trial by jury
on all issues triable by a jury.
20
PRAYER FOR RELIEF
Estech Systems IP, LLC requests that the Court find in its favor and against Defendants,
and that the Court grant Estech the following relief:
a. Judgment that one or more claims of the Asserted Patents have been infringed,
either literally or under the doctrine of equivalents, by Defendants or all others acting in concert
therewith;
b. A permanent injunction enjoining Defendants and their officers, directors, agents,
servants, affiliates, employees, divisions, branches, subsidiaries, parents, and all others acting in
concert therewith from infringement of the ’298, ’684, and ’699 patents; or, in the alternative, an
award of a reasonable ongoing royalty for future infringement of the Asserted Patents by such
entities;
c. Judgment that Defendants account for and pay to Estech all damages to and costs
incurred by Estech because of Defendants’ infringing activities and other conduct complained of
herein;
d. Judgment that Defendants’ infringements be found willful, and that the Court award
treble damages for the period of such willful infringement pursuant to 35 U.S.C. § 284;
e. Pre-judgment and post-judgment interest on the damages caused by Defendants’
infringing activities and other conduct complained of herein;
f. That this Court declare this an exceptional case and award Estech its reasonable
attorneys’ fees and costs in accordance with 35 U.S.C. § 285; and
g. All other and further relief as the Court may deem just and proper under the
circumstances.
21
Dated: January 4, 2022 Respectfully submitted,
By: /s/ Fred I. Williams

Fred I. Williams
Texas State Bar No. 00794855
Michael Simons
Texas State Bar No. 24008042
WILLIAMS SIMONS & LANDIS PLLC
The Littlefield Building
601 Congress Ave., Suite 600
Austin, TX 78701
Tel: 512-543-1354
[email protected]
[email protected]
Todd E. Landis
State Bar No. 24030226
2633 McKinney Ave., Suite 130 #366
Dallas, TX 75204
Tel: 512-543-1357
[email protected]
John Wittenzellner
Pennsylvania State Bar No. 308996
1735 Market Street, Suite A #453
Philadelphia, PA 19103
Tel: 512-543-1373
[email protected]
Attorneys for Plaintiff Estech Systems IP, LLC
22

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Case 2:22-cv-00003-JRG-RSP Document 1 Filed 01/04/22 Page 1 of 22 PageID #: 1

IN THE UNITED STATES DISTRICT COURT

ESTECH SYSTEMS IP, LLC, CIVIL ACTION NO. 2:22-cv-00003

Plaintiffs, ORIGINAL COMPLAINT FOR

BAYERISCHE MOTOREN WERKE AG JURY TRIAL DEMANDED

ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT

information and belief as to all other matters, as follows:

at 3701 East Plano Parkway, Suite 300, Plano, Texas 75074.

2. Defendant Bayerische Motoren Werke AG is a corporation organized and existing

3. Defendant BMW of North America, LLC is a corporation organized and existing

Bryan Street, Suite 900, Dallas, TX 75201-3136.

JURISDICTION AND VENUE

under 28 U.S.C. § 1331 and § 1338(a).

5. Venue is proper in this district pursuant to 28 U.S.C. §§ 1400(b) and 1391(b-c).

district with personal jurisdiction over it.

6. Defendant Bayerische Motoren Werke AG is subject to this Court’s specific

United States, including from customers residing in the District.

7. Defendant Bayerische Motoren Werke AG is also subject to this Court’s specific

provided to individuals in Texas and in this district.

provided to individuals in Texas and in this district.

9. Specifically, Defendants intend to and do business in Texas, directly or through

district, including at 6800 Dallas Parkway, Plano, Texas 75024.

Network Operations Center is located in Plano, Texas.

businesses across the country.

and fuels customer satisfaction.

14. ES Inc.’s technology is American-engineered. From its Plano, Texas headquarters,

infrastructure to provide communication services, such as telephony services.

Internet or private networks, using the Internet Protocol (IP).

communication services that can be integrated with a VoIP telephony system.

forth in their entirety.

the VoIP telephony system.

device to observe a list of a plurality of telecommunications extensions. The list of extensions is

limited to well-understood, routine, or conventional activity. Rather, the claimed inventions

VoIP telephone systems and networking equipment utilized by Defendants (“Accused

networking services to VoIP telephony devices.

telecommunications extensions being coupled to the second and third LANs.

telecommunications extensions in response to a user selecting one of the telecommunications

telecommunications extensions coupled to the second LAN or the third LAN.

telecommunications extensions accessed across the WAN.

costs as fixed by this Court under 35 U.S.C. § 284.

35. Estech or its predecessors-in-interest have satisfied all statutory obligations

promoting the use of the Accused Instrumentalities in an infringing manner; or distributing

would infringe the ’298 patent. Defendants’ inducement is ongoing.

substantial non-infringing use. Defendants’ contributory infringement is ongoing.

continues to be willful, intentional, deliberate, or in conscious disregard of Estech’s rights under

costs as fixed by this Court under 35 U.S.C. § 284.

relief in this case.

forth in their entirety.

a workstation connected to the VoIP telephone.

function and operation of information processing systems.

VoIP telephone systems and networking equipment utilized by Defendants (“Accused

networking services to VoIP telephony devices.

example, websites) that transfer data through VoIP telephony devices.

interest and costs as fixed by this Court under 35 U.S.C. § 284.

56. Estech or its predecessors-in-interest have satisfied all statutory obligations

promoting the use of the Accused Instrumentalities in an infringing manner; or distributing

would infringe the ’684 patent. Defendants’ inducement is ongoing.

contributory infringement is ongoing.

continues to be willful, intentional, deliberate, or in conscious disregard of Estech’s rights under

costs as fixed by this Court under 35 U.S.C. § 284.

relief in this case.

forth in their entirety.

information processing systems.