Lone Star Wifi v. Omni Hotels et. al

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PLAINTIFF LONE STAR WIFI LLC’S COMPLAINT FOR PATENT INFRINGEMENT

Jaime K. Olin (SBN 243139) [email protected] Brent N. Bumgardner (Pro Hac pending) [email protected] Edward R. Nelson, III (Pro Hac pending) [email protected] Jonathan H. Rastegar (Pro Hac pending) [email protected] Nelson Bumgardner Casto, P.C. 3131 West 7th Street, Suite 300 Fort Worth, TX 76107 Telephone: (817) 377-9111 Facsimile: (817) 377-3485 Attorneys for Plaintiff, LONE STAR WIFI LLC

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF CALIFORNIA

LONE STAR WIFI LLC, Plaintiff; v. OMNI HOTELS CORPORATION AND OMNI HOTELS MANAGEMENT CORPORATION,

Defendants.

Case No.

PLAINTIFF LONE STAR WIFI’S COMPLAINT FOR PATENT INFRINGEMENT Demand for Jury Trial

Plaintiff Lone Star WiFi LLC, by counsel, alleges as follows:

THE PARTIES

1. Plaintiff Lone Star WiFi LLC (“Lone Star WiFi”) is a Texas limited

liability company with a principal place of business at 100 E. Ferguson, Suite 806,

Tyler, TX 75702.

'14CV0804 NLSBEN

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PLAINTIFF LONE STAR WIFI LLC’S COMPLAINT FOR PATENT INFRINGEMENT -2-

2. Omni Hotels Corporation is a Delaware corporation with its principal

place of business at 4001 Maple Ave., Dallas, Texas 75219. Omni Hotels

Corporation can be served through Corporation Service Company, 2711 Centerville

Rd., Suite 400, Wilmington, DE 19808. Upon information and belief, Omni Hotels

Corporation does business in the State of California and in the Southern District of

California.

3. Omni Hotels Management Corporation is a Delaware corporation with

its principal place of business at 420 Decker Drive, Irving, Texas 75062. Omni

Hotels Management Corporation can be served through its registered agent at CSC,

2710 Gateway Oaks Drive, Suite 150N, Sacramento, CA 95833. Upon information

and belief, Omni Hotels Management Corporation does business in the State of

California and in the Southern District of California.

4. Omni Hotels Corporation and Omni Hotels Management Corporation

are collectively referred to herein as “Omni” or “Defendants.”

JURISDICTION AND VENUE

5. This is a civil action for patent infringement arising under the United

States patent statutes, 35 U.S.C. § 1 et seq.

6. This Court has jurisdiction over the subject matter of this action under

28 U.S.C. §§ 1331 and 1338(a).

7. This Court has personal jurisdiction over Defendants by virtue of

Defendants’ activities within this judicial district. Upon information and belief,

Defendants offer products and services within this judicial district, and specifically

target their activities to residents of this judicial district. Defendants are subject to

this Court’s specific and general personal jurisdiction pursuant to due process

and/or the California Long Arm Statute, due at least to their substantial, continuous,

and systematic business in this State and judicial district, including: (A) at least part

of the infringing activities alleged herein; and (B) regularly doing or soliciting

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business, engaging in other persistent conduct, and/or deriving substantial revenue

from goods sold and services provided to California residents.

8. Venue is proper in this judicial district pursuant to 28 U.S.C. §§

1391(b) - (d). On information and belief, each Defendant is deemed to reside in

this judicial district, and has regularly and purposefully advertised, solicited, and

transacted business in this judicial district, including business related to the accused

products and services.

BACKGROUND FACTS & PATENTS-IN-SUIT

Wireless Access and the Patents-in-Suit.

9. This suit involves United States Patent Nos. 7,490,348; 8,312,286; and

8,583,935 (collectively, the “Patents-in-Suit”). The Patents-in-Suit are generally

directed to particular implementations of wireless networks in which multiple,

overlapping wireless streams provide varying levels of access to content and

resources.

10. On March 17, 2003, inventor Scott C. Harris filed Provisional Patent

Application No. 60/454,694.

11. On the basis of that priority, Mr. Harris filed Patent Application No.

10/800,472 on March 15, 2004.

12. On February 10, 2009, the United States Patent and Trademark Office

granted Mr. Harris’s application, duly and legally issuing United States Patent No.

7,490,348 (the “’348 Patent”), entitled “Wireless Network Having Multiple

Communication Allowances,” to Harris Technology LLC. A copy of the ’348

Patent is attached as Exhibit A.

13. On November 13, 2012, the United States Patent and Trademark

Office duly and legally issued United States Patent No. 8,312,286 (the “’286

Patent”), entitled “Wireless Network Having Multiple Communication

Allowances,” to Harris Technology LLC. A copy of the ’286 Patent is attached as

Exhibit B.

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14. On November 12, 2013, the United States Patent and Trademark

Office duly and legally issued United States Patent No. 8,583,935 (the “’935

Patent”), entitled “Wireless Network Having Multiple Communication

Allowances,” to Lone Star WiFi LLC. A copy of the ’935 Patent is attached as

Exhibit C.

Hotels Need to Provide Multiple Wireless Networks to Satisfy Their Guests

and Remain Competitive.

15. Wireless Internet access has become one of the most critical amenities

– if not the most critical amenity – hotels offer to their guests.

16. Several national publications and news services run periodic surveys

regarding the hospitality industry.

17. Hotel chains, hotel owners, and hotel management companies such as

Defendants participate in and trust the results of such surveys to help inform their

business decision-making.

18. Indeed, hotels often cite positive findings from such surveys in their

own advertising and marketing materials as evidence to potential customers why

their brands and/or properties are superior.

19. Such surveys have found overwhelming growth in the need for, and

the provision of, wireless Internet access in hotel guest rooms.

20. For example, J.D. Power and Associates is a well-known global

marketing information services company that provides customer satisfaction

research and market research regarding a number of industries.

21. Each year for the past seventeen years, J.D. Power and Associates has

conducted and published a study of consumer satisfaction with various hotel chains.

22. Omni has cited complimentary results from the J.D. Power annual

survey.

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23. For each of the last six years, the J.D. Power survey has found the

trend regarding wireless Internet access at hotels important enough to report on it as

part of the primary press release regarding the survey.

24. In its 2010 annual survey, J.D. Power found that wireless Internet

access led the “top five ‘must-have’ amenities for hotel guests.”

25. The 2010 survey reported that hotel properties had “increased

offerings of wireless Internet access during the past several years, with 77 percent

of guests in 2010 indicating they have used Wi-Fi rather than cable Internet

connections in their guest room, compared with 55 percent in 2007.”

26. Mark Schwartz, director of the global hospitality and travel practice at

J.D. Power, commented regarding the 2010 survey that, “guests are starting to

expect wireless Internet access in their hotel rooms,” because “[i]n today’s digitally

connected world, being able to use mobile devices or computers without

interruption is considered a comfort of home that should extend to the hotel

experience.”

27. In its 2011 annual survey, J.D. Power noted the disproportionally high

report rate for problems with hotel Internet service: “[N]oise is the problem most

commonly experienced by guests, with 16 percent indicating experiencing the

issue. However, only 43 percent of these guests indicate they reported the noise to

hotel staff. In contrast, just 13 percent of guests say they experienced a problem

with the Internet connection or speed at their hotel, but 60 percent reported the

problem.”

28. Indeed, guests cared so much about the wireless Internet access at

hotels in 2012, J.D. Power found they “use[d] social media to complain about how

slow Internet connections are at hotels,” and also “to praise hotel brands that are

known for fast, reliable Internet service.”

29. In its 2013 annual survey, J.D. Power noted that “[w]hile Internet

usage during a hotel stay continues to steadily increase, it remains the top problem

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experienced by guests. Among guests who experienced a problem during their

hotel stay, 31 percent had an issue with their Internet service in terms of connection

and/or speed. Interestingly, overall satisfaction among guests who experienced

difficulties connecting to the Internet is 133 points lower than among those who did

not have problems, whether Internet access was included in the room rate or not.”

30. Another example of a national service reporting data regarding the

hotel industry is TripAdvisor. TripAdvisor claims to be the world’s largest travel

website, aggregating reviews and advice regarding airlines, hotels, restaurants, and

other travel features worldwide.

31. In a February 17, 2011 survey, TripAdvisor polled over 1,000 U.S.

accommodation owners – hoteliers, B&B owners and innkeepers – regarding their

plans to attract travelers in 2011 and increase repeat customers.

32. In the February 2011 survey, only four percent of the owners indicated

they had no plans to offer in-room Internet access, which TripAdvisor referred to as

“a key consumer demand.”

33. In January 2012, TripAdvisor conducted a “360 degree survey,” which

polled 1,248 U.S. travelers and 622 U.S. hotel managers and owners.

34. TripAdvisor’s 360 degree survey found that wireless Internet access

was the most important hotel amenity among eighty-five percent of travelers who

most often booked hotels.

35. Moreover, in that same 360 degree survey, TripAdvisor found that

ninety-nine percent of hotel owners and managers considered wireless Internet

access the most important amenity.

36. Even more recently, in July 2012 TripAdvisor released the results of

its biannual “Industry Index,” incorporating responses from 25,517 accommodation

owners and managers worldwide.

37. Eighty-one percent of hoteliers in North America reported being

profitable over the six month period prior to the Industry Index survey, conducted

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during June 2012, while thirty percent of U.S. accommodation owners reported

their businesses were “extremely profitable” or “very profitable” over that period.

38. Of the properties that did not currently offer in-room WiFi in June

2012, thirty-six percent indicated they planned to add that feature in the next six

months.

39. Like TripAdvisor, Hotels.com is an Internet service that provides

reservation services and information for travelers about prospective destinations.

Hotels.com conducts periodic surveys on traveler satisfaction and opinions.

40. In January 2012, Hotels.com conducted a survey regarding travelers’

preferences in hotel amenities. In response to “[q]uestion after question, guests

reported that free Wi-Fi [wa]s a must when choosing a hotel room and that this

amenity overwhelmingly factored into the decision on which hotel to book.”

41. But it is not just third parties who have noticed the ever-increasing

importance of providing wireless Internet access in hotel guest rooms. Hotel chains

and their executives—including Omni itself—have also noticed the trend

themselves.

42. Omni was one of the first hotel chains to offer free WiFi to guests.

43. Omni saw free Wi-Fi access as a way to maintain customer loyalty,

company spokeswoman Christine Connelly said. “The company wanted to ‘keep it

simple’ for guests,” she said, “rather than nickel and dime them to death."

44. On February 14, 2012, the Travel section of USA Today reported the

results of a roundtable discussion between five hotel CEOs the newspaper had

conducted when they were gathered together for the Americas Lodging Investment

Summit in January. Each CEO was asked what his hotel was doing in response to

Internet access becoming a top amenity for travelers.

45. Former Marriott CEO J.W. “Bill” Marriott Jr. commented that, “It’s a

huge problem. Everyone wants to talk in the room and they want to download

everything they can. It’s getting to be quite a challenge.”

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46. Richard Solomons, CEO of InterContinental Hotels Group, agreed that

“We all see it as an issue. It’s one of the big dissatisfiers that you see in a lot of

hotels.”

47. Former Carlson CEO Hubert Joly responded that, “Free Internet is the

greatest demand in terms of amenities of the travelers. It’s almost like having water

or air conditioning in the room.”

48. Choice Hotels CEO Steve Joyce added that “Whether you charge [for

wireless Internet access] or whether it’s free, you’d better have some dependability

and reliability because it will become the single source of complaints.”

49. When asked by the Wall Street Journal in a June 15, 2012 interview

what amenities she saw spreading in the industry, Four Seasons Chief Executive

Officer KathleenTaylor responded that “Technology is one of the leading edge

issues for consumers in all segments. It’s less an amenity and more like hot water,

in the sense that everyone is expected to have it.”

50. On August 20, 2012, hotel chain Starwood Hotels and Resorts

Worldwide, Inc. issued a press release entitled, “Four Points by Sheraton Survey

Reveals Mobile Device Habits of Business Travelers Worldwide.” See,

<http://www.businesswire.com/news/home/20120820005808/en/Points-Sheraton-

Survey-Reveals-Mobile-Device-Habits>.

51. In the August 2012 release, Starwood explained that its brand Four

Points by Sheraton had commissioned a hotel business and technology study in

which 6,000 business travelers, including 1,000 from the United States, were

surveyed.

52. According to the August 2012 press release, the Four Points by

Sheraton survey found that, irrespective of nationality, the majority of respondents

brought three or four mobile, wireless-capable devices with them on the road.

53. Those devices most often included a smartphone, followed by tablet

computers, music players, and laptops.

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54. The Four Points by Sheraton survey found that checking their

smartphone was the most common activity respondents undertook first upon

waking up in their hotel. Checking Facebook and Twitter also ranked among the

top five post-wake up activities.

55. Business traveler respondents to the Four Points by Sheraton survey

explained their primary purposes for traveling with mobile devices were to keep up

with email, Internet browsing and social networking, and maintaining

communications with their office.

56. Over sixty percent of the business traveler respondents to the Four

Points by Sheraton survey said they believed traveling with technology makes their

lives significantly easier and more convenient.

57. In the August 2012 press release about the Four Points by Sheraton

survey, Starwood’s senior vice president, specialty select brands, Brian

McGuinness, called the results of the study “compelling.”

58. Mr. McGuinness concluded the Four Points by Sheraton survey

“affirms that the Four Points brand is meeting a continued need by offering

complimentary WiFi or in-room Internet access, and by continuing to expand

bandwidth throughout the portfolio.”

59. The availability and reliability of wireless Internet access is not only

important with respect to the ability to fill guest rooms. It also impacts the ability

to book meeting spaces as an additional source of revenue.

60. In 2010, the late Steve Jobs was famously forced to ask the audience at

Apple’s developer conference to shut off their laptops and phones after his

introduction of the iPhone 4 was derailed because of an overloaded Wi-Fi network.

Since then, venues that hold meetings and trade shows have been increasingly

cognizant of their wireless Internet capabilities.

61. Earlier this year, the New York Times published an article entitled,

“The Trade Show, Updated,” which reported inter alia that, “[h]otels that do

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lucrative meetings and conference business are also increasingly seeing the need to

improve their technology.”

62. In particular, Brad Weaber, the executive vice president for event

services at SmithBucklin, a company that arranges conventions and meetings of all

kinds, commented that “Today, you can’t not have full connectivity for your

attendees or they won’t come.”

63. Moreover, in an effort to keep guests and meeting attendees—and their

associated spending on drinks, food, and other incidentals—within the bounds of

their properties, hotel chains have increasingly sought to make their lobbies and

common spaces more desirable as places to work and socialize. Part of this effort

has been ensuring the availability of wireless Internet access in such common areas.

64. For example, when asked by USA Today about the effort to

“reinvent[] lobbies to make them inviting, social places,” Bill Marriott Jr.

confirmed that, “The feedback is terrific, because it’s an opportunity to socialize,

have something quick to eat, sit in the lobby and work on your computer. At this

hotel here (LA Live), you look at the people in all their little pods and areas talking,

meeting, visiting and eating. It’s a socialization of the lobby, which has never

happened before in our industry, because people used to go in the lobby, check in,

check out and then leave. Today, they’re all over the lobby, and they’re coming

back to the hotel and using the lobby for a drink afterward.”

Defendants Own and/or Manage Omni Hotel and Resorts

65. Omni is an increasingly visible, well-known hotel chain.

66. Omni owns and/or manages 50 hotels and resorts in North America, 46

of which are located in the United States.

67. Omni’s ownership responsibilities typically include hiring, training

and supervising the managers and employees that operate the facilities. This would

include technical employees who design, implement, and maintain the facilities’

wireless networks and/or oversee vendors performing such services.

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68. Upon information and belief, Omni controls centralized reservation

services and coordinated national and international advertising and certain

marketing and promotional services.

69. Upon information and belief, Omni also prepares and implements

annual budgets for its hotels and resorts and allocates funds for periodic

maintenance and repair of buildings and furnishings.

70. Upon information and belief, Omni employs technical personnel to

design, implement, and maintain the facilities’ wireless networks and/or oversee

vendors performing such services.

71. Omni created and maintains a “Select Guest” loyalty program. The

program offers “complimentary perks including in-room Wi-Fi, pressings, shoe

shine, morning beverage delivery and so much more.” The “Select Guest” loyalty

program is free for members to join.

72. Omni’s Select Guest program brochure advertises “Complimentary

3MB Wi-Fi Service” first in a list of Benefits enjoyed by members.

The Multiple, Overlapping Wireless Networks Maintained at Omni’s Hotel

and Resorts Infringe the Patents-in-Suit.

73. Upon information and belief, all of Omni’s hotels and resorts maintain

multiple, overlapping wireless networks.

74. Upon information and belief, Omni creates and maintains brand

standards for its hotels and resorts.

75. Omni identifies Stephen Rosenstock as the Senior Vice President in

charge of brand standards (“Rosenstock also maintains and develops brand

standards for Omni Hotels & Resorts’ guest rooms and other operational areas to

ensure compelling brand differentiation.”).

76. Brand standards are used in the hotel industry to ensure that individual

properties in hotel chains implement and maintain certain aspects of the properties’

exterior appearance, facilities, guest rooms, etc., in a manner consistent with the

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hotel brand. One such aspect that is commonly covered by brand standards is

provision, implementation, and maintenance of wireless Internet access.

77. Upon information and belief, Omni propounds brand standards for its

hotels and resorts that includes mandated standards for the provision,

implementation and maintenance of wireless Internet access.

OMNI INTERNET ACCESS AT ITS HOTELS AND RESORTS

78. Omni maintains network infrastructures comprising multiple

overlapping networks at its hotels and resorts, including wired and wireless

networks. The networks are configured to provide different methods of access and

levels of service.

79. Such networks may include lobby networks.

80. Such networks may include guest networks.

81. Such networks may include conference room networks.

82. Such networks may include private, secure networks.

83. Such network configurations are provided by Omni for the benefit of

guests, patrons, and employees.

OMNI HOTELS

84. Omni owns 34 hotels in the United States.

Omni San Diego Hotel

85. Omni owns the Omni San Diego Hotel, which is a hotel facility

located at 675 L Street, San Diego, CA 92101.

86. The Omni San Diego Hotel has 511 guest rooms, including a number

of suites.

87. The Omni San Diego Hotel also includes 21 conference rooms and one

ballroom, a collective 27,000 square feet of meeting space used to host events

ranging from small board meetings to wedding receptions to major sales functions.

88. As Omni displays on its website, for access to the wireless network in

and around the Omni San Diego Hotel public areas, Omni provides “free high-

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speed in all public areas. . .” for “member[s] of [Omni’s] Select Guest loyalty

program.”

89. As Omni displays on its website, for the wireless network in and

around its non-public areas and meeting rooms at the Omni San Diego Hotel, Omni

offers access “for a nominal charge.”


and around its guest rooms at the Omni San Diego Hotel, Omni provides free high-

speed for members of its Select Guest loyalty program, and for guests who are not

Select Guest members, “you can still stay connected while in your guest room with

our Internet access for a nominal $9.95 per day plus tax.”

Omni Los Angeles Hotel at California Plaza

91. Omni owns the Omni Los Angeles Hotel at California Plaza, which is

a hotel facility located at 251 South Olive St., Los Angeles, CA 90012.

92. The Omni Los Angeles Hotel at California Plaza has 453 guest rooms,

including a number of suites.

93. The Omni Los Angeles Hotel at California Plaza also includes 22

conference rooms and one ballroom, a collective 20,000 square feet of meeting

space used to host events ranging from small board meetings to wedding receptions

to major sales functions.


and around the Omni Los Angeles Hotel at California Plaza public areas, Omni

provides “free high-speed in all public areas. . .” for “member[s] of [Omni’s] Select

Guest loyalty program.”


around its non-public areas and meeting rooms at the Omni Los Angeles Hotel at

California Plaza, Omni offers access “for a nominal charge.”


and around its guest rooms at the Omni Los Angeles Hotel at California Plaza,

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Omni provides free high-speed for members of its Select Guest loyalty program,

and for guests who are not Select Guest members, “you can still stay connected

while in your guest room with our Internet access for a nominal $9.95 per day plus

tax.”

Omni San Francisco Hotel

97. Omni owns the Omni San Francisco Hotel, which is a hotel facility

located at 500 California Street, San Francisco, CA 94104.

98. The Omni San Francisco Hotel has 362 guest rooms, including a

number of suites.

99. The Omni San Francisco Hotel also includes 7 conference rooms and

one ballroom, a collective 11,000 square feet of meeting space used to host events



and around the Omni San Francisco Hotel public areas, Omni provides “free high-


program.”


around its non-public areas and meeting rooms at the Omni San Francisco Hotel,

Omni offers access “for a nominal charge.”


and around its guest rooms at the Omni San Francisco Hotel, Omni provides free

high-speed for members of its Select Guest loyalty program, and for guests who are

not Select Guest members, “you can still stay connected while in your guest room

with our Internet access for a nominal $14.95 per day plus tax for the basic 3 MB

access or $19.95 (per day plus tax) for the upgraded 6MB connection.”

Omni Dallas Hotel at Park West

103. Omni owns the Omni Dallas Hotel at Park West, which is a hotel

facility located at 1590 LBJ Freeway, Dallas, TX 75234.

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104. The Omni Dallas Hotel at Park West has 337 guest rooms, including a

number of suites.

105. The Omni Dallas Hotel at Park West also includes 8 conference suites

and 2 ballrooms, a collective 17,000 square feet of meeting space used to host

events ranging from small board meetings to wedding receptions to major sales

functions.


and around the Omni Dallas Hotel at Park West public areas, Omni provides “free

high-speed in all public areas. . .” for “member[s] of [Omni’s] Select Guest loyalty

program.”


around its non-public areas and meeting rooms at the Omni Dallas Hotel at Park

West, Omni offers access “for a nominal charge.”


and around its guest rooms at the Omni Dallas Hotel at Park West, Omni provides

free high-speed for members of its Select Guest loyalty program, and for guests

who are not Select Guest members, “you can still stay connected while in your

guest room with our Internet access for a nominal $9.95 per day plus tax.”

Omni Mandalay Hotel at Las Colinas

109. Omni owns the Omni Mandalay Hotel at Las Colinas, which is a hotel

facility located at 221 E. Las Colinas Blvd., Dallas, TX 75039.

110. The Omni Mandalay Hotel at Las Colinas has 421 guest rooms,


111. The Omni Mandalay Hotel at Las Colinas also includes 23 conference

rooms and at least one ballroom, a collective 31,000 square feet of meeting space

used to host events ranging from small board meetings to wedding receptions to

major sales functions.

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and around the Omni Mandalay Hotel at Las Colinas public areas, Omni provides

“free high-speed in all public areas. . .” for “member[s] of [Omni’s] Select Guest

loyalty program.”


around its non-public areas and meeting rooms at the Omni Mandalay Hotel at Las

Colinas, Omni offers access “for a nominal charge.”


and around its guest rooms at the Omni Mandalay Hotel at Las Colinas, Omni

provides free high-speed for members of its Select Guest loyalty program, and for

guests who are not Select Guest members, “you can still stay connected while in

your guest room with our Internet access for a nominal $9.95 per day plus tax.”

Omni Dallas Hotel

115. Omni owns the Omni Dallas Hotel, which is a hotel facility located at

555 S. Lamar, Dallas, TX 75202.

116. The Omni Dallas Hotel has 1,001 guest rooms, including 67 suites.

117. The Omni Dallas Hotel also includes 39 conference rooms, a collective

110,000 square feet of meeting space used to host events ranging from small board

meetings to wedding receptions to major sales functions.


and around the Omni Dallas Hotel public areas, Omni provides “free high-speed in

all public areas and free tier-one level speed in your guest room. . .” for “member[s]

of [Omni’s] Select Guest loyalty program” and “additional bandwidth may be

purchased at a discounted rate for our Select Guest loyalty members.”


around its non-public areas and meeting rooms at the Omni Dallas Hotel, Omni


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and around its guest rooms at the Omni Dallas Hotel, Omni provides free high-




Omni Fort Worth Hotel

121. Omni owns the Omni Fort Worth Hotel, which is a hotel facility

located at 1300 Houston Street, Fort Worth, TX 76102.

122. The Omni Fort Worth Hotel has 614 guest rooms, including a number

of suites.

123. The Omni Fort Worth Hotel also includes 29 conference rooms, a

collective 68,000 square feet of meeting space used to host events ranging from

small board meetings to wedding receptions to major sales functions.


and around the Omni Fort Worth Hotel public areas, Omni provides “free high-


program.”


around its non-public areas and meeting rooms at the Omni Fort Worth Hotel,



and around its guest rooms at the Omni Fort Worth Hotel, Omni provides free high-

speed for members of its Select Guest loyalty program.

Omni Houston Hotel

127. Omni owns the Omni Houston Hotel, which is a hotel facility located

at Four Riverway, Houston, TX 77056.

128. The Omni Houston Hotel has 378 guest rooms, including 33 suites.

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129. The Omni Houston Hotel also includes 12 conference rooms and one




and around the Omni Houston Hotel public areas, Omni provides “free high-speed

in all public areas. . .” for “member[s] of [Omni’s] Select Guest loyalty program.”


around its non-public areas and meeting rooms at the Omni Houston Hotel, Omni



and around its guest rooms at the Omni Houston Hotel, Omni provides free high-




Omni Houston Hotel at Westside

133. Omni owns the Omni Houston Hotel at Westside, which is a hotel

facility located at 13210 Katy Freeway, Houston, TX 77079.

134. The Omni Houston Hotel at Westside has 400 guest rooms, including a

number of suites.

135. The Omni Houston Hotel at Westside also includes 25 conference

rooms and one ballroom, a collective 25,000 square feet of meeting space used to

host events ranging from small board meetings to wedding receptions to major sales

functions.


and around the Omni Houston Hotel at Westside public areas, Omni provides “free


program.”

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around its non-public areas and meeting rooms at the Omni Houston Hotel at

Westside, Omni offers access “for a nominal charge.”


and around its guest rooms at the Omni Houston Hotel at Westside, Omni provides




Omni Austin Hotel Downtown

139. Omni owns the Omni Austin Hotel Downtown, which is a hotel

facility located at 700 San Jacinto at 8th St., Austin, TX 78701.

140. The Omni Austin Hotel Downtown has 392 guest rooms, including 91

suites.

141. The Omni Austin Hotel Downtown also includes 16 conference rooms

and ballrooms, a collective 20,000 square feet of meeting space used to host events



and around the Omni Austin Hotel Downtown public areas, Omni provides “free


program.”


around its non-public areas and meeting rooms at the Omni Austin Hotel

Downtown, Omni offers access “for a nominal charge.”


and around its guest rooms at the Omni Austin Hotel Downtown, Omni provides




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Omni Austin Hotel at Southpark

145. Omni owns the Omni Austin Hotel at Southpark, which is a hotel

facility located at 4140 Governor’s Row, Austin, TX 78744.

146. The Omni Austin Hotel at Southpark has 312 guest rooms, including a

number of suites.

147. The Omni Austin Hotel at Southpark also includes 13 conference

rooms, a collective 13,677 square feet of meeting space used to host events ranging

from small board meetings to wedding receptions to major sales functions.


and around the Omni Austin Hotel at Southpark public areas, Omni provides

“complimentary 3 MB high-speed in all public areas. . .” for “member[s] of

[Omni’s] Select Guest loyalty program,” with “faster download speeds of up to 6

MB premium Wifi upgrade at $4.95 per 24 hours [] now available.”


around its non-public areas and meeting rooms at the Omni Austin Hotel at

Southpark, Omni offers access “for a nominal charge.”


and around its guest rooms at the Omni Austin Hotel at Southpark, Omni provides



guest room with our Internet access for a nominal $9.95 per day plus tax or $14.95

per day plus tax for our 6 MB service.”

Omni Corpus Christi Hotel

151. Omni owns the Omni Corpus Christi Hotel, which is a hotel facility

located at 900 North Shoreline Blvd., Corpus Christi, TX.

152. The Omni Corpus Christi Hotel has 475 guest rooms, including a

number of suites.

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153. The Omni Corpus Christi Hotel also includes 11 conference rooms and




and around the Omni Corpus Christi Hotel public areas, Omni provides “free high-


program.”


around its non-public areas and meeting rooms at the Omni Corpus Christi Hotel,



and around its guest rooms at the Omni Corpus Christi Hotel, Omni provides free



with our Internet access for a nominal $9.95 per day plus tax.”

Omni La Mansion del Rio

157. Omni owns the Omni La Mansion del Rio, which is a hotel facility

located at 112 College St., San Antonio, TX 78205.

158. The Omni La Mansion del Rio has 338 guest rooms, including a

number of suites.

159. The Omni La Mansion del Rio also includes 16 conference rooms and




and around the Omni La Mansion del Rio public areas, Omni provides “free high-


program.”

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around its non-public areas and meeting rooms at the Omni La Mansion del Rio,



and around its guest rooms at the Omni La Mansion del Rio, Omni provides free




Omni San Antonio Hotel at the Colonnade

163. Omni owns the Omni San Antonio Hotel at the Colonnade, which is a

hotel facility located at 9821 Colonnade Blvd., San Antonio, TX 78230.

164. The Omni San Antonio Hotel at the Colonnade has 326 guest rooms,


165. The Omni San Antonio Hotel at the Colonnade also includes 15

conference rooms and one ballroom, a collective 23,000 square feet of meeting

space used to host events ranging from small board meetings to wedding receptions

to major sales functions.


and around the Omni San Antonio Hotel at the Colonnade public areas, Omni

provides “free high-speed in all public areas. . .” for “member[s] of [Omni’s] Select

Guest loyalty program.”


around its non-public areas and meeting rooms at the Omni San Antonio Hotel at

the Colonnade, Omni offers access “for a nominal charge.”


and around its guest rooms at the Omni San Antonio Hotel at the Colonnade, Omni

provides free high-speed for members of its Select Guest loyalty program, and for

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guests who are not Select Guest members, “you can still stay connected while in

your guest room with our Internet access for a nominal $9.95 per day plus tax.”

Mokara Hotel & Spa

169. Omni owns the Mokara Hotel & Spa, which is a hotel facility located

at 212 West Crockett St., San Antonio, TX 78205.

170. The Mokara Hotel & Spa has a number of guest rooms, including a

number of suites.

171. The Mokara Hotel & Spa also includes 6 conference rooms, a




and around the Mokara Hotel & Spa guest rooms, Omni provides “complimentary

in-room wireless Internet access.”

Omni Hotel at CNN Center

173. Omni owns the Omni Hotel at CNN Center, which is a hotel facility

located at 100 CNN Center, Atlanta, GA 30303.

174. The Omni Hotel at CNN Center has 1,070 guest rooms, including a

number of suites.

175. The Omni Hotel at CNN Center also includes 45 conference rooms

and ballrooms, a collective 120,000 square feet of meeting space used to host


functions.


and around the Omni Hotel at CNN Center public areas, Omni provides “free high-


program.”

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around its non-public areas and meeting rooms at the Omni Hotel at CNN Center,



and around its guest rooms at the Omni Hotel at CNN Center, Omni provides free




Omni Parker House

179. Omni owns the Omni Parker House, which is a hotel facility located at

60 School Street, Boston, MA 02108.

180. The Omni Parker House has 551 guest rooms, including a number of

suites.

181. The Omni Parker House also includes 18 conference rooms and one




and around the Omni Parker House public areas, Omni provides “free high-speed in

all public areas. . .” for “member[s] of [Omni’s] Select Guest loyalty program.”


around its non-public areas and meeting rooms at the Omni Parker House, Omni



and around its guest rooms at the Omni Parker House, Omni provides free high-




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Omni Charlotte Hotel

185. Omni owns the Omni Charlotte Hotel, which is a hotel facility located

at 132 E. Trade St., Charlotte, NC 28202.

186. The Omni Charlotte Hotel has 374 guest rooms, including a number of

suites.

187. The Omni Charlotte Hotel also includes 13 conference rooms and one




and around the Omni Charlotte Hotel public areas, Omni provides “free high-speed



around its non-public areas and meeting rooms at the Omni Charlotte Hotel, Omni



and around its guest rooms at the Omni Charlotte Hotel, Omni provides free high-




Omni Charlottesville Hotel

191. Omni owns the Omni Charlottesville Hotel, which is a hotel facility

located at 212 Ridge McIntire Road, Charlottesville, VA 22903.

192. The Omni Charlottesville Hotel has 208 guest rooms, including a

number of suites.

193. The Omni Charlottesville Hotel also includes 16 conference rooms and



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and around the Omni Charlottesville Hotel public areas, Omni provides “free high-


program.”


around its non-public areas and meeting rooms at the Omni Charlottesville Hotel,



and around its guest rooms at the Omni Charlottesville Hotel, Omni provides free




Omni Chicago Hotel

197. Omni owns the Omni Chicago Hotel, which is a hotel facility located

at 676 North Michigan Ave., Chicago, IL 60611.

198. The Omni Chicago Hotel has 347 guest suites.

199. The Omni Chicago Hotel also includes 9 conference rooms, a




and around the Omni Chicago Hotel public areas, Omni provides “free high-speed



around its non-public areas and meeting rooms at the Omni Chicago Hotel, Omni



and around its guest rooms at the Omni Chicago Hotel, Omni provides free high-


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Omni Interlocken Hotel

203. Omni owns the Omni Interlocken Hotel, which is a hotel facility

located at 500 Interlocken Blvd., Denver, CO 80021.

204. The Omni Interlocken Hotel has 390 guest rooms, including a number

of suites.

205. The Omni Interlocken Hotel also includes 14 conference rooms and




and around the Omni Interlocken Hotel public areas, Omni provides “free high-


program.”


around its non-public areas and meeting rooms at the Omni Interlocken Hotel,



and around its guest rooms at the Omni Interlocken Hotel, Omni provides free high-




Omni Severin Hotel

209. Omni owns the Omni Severin Hotel, which is a hotel facility located at

40 W. Jackson Place, Indianapolis, IN 46225.

210. The Omni Severin Hotel has 424 guest rooms, including a number of

suites.

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211. The Omni Severin Hotel also includes 17 conference rooms and one




and around the Omni Severin Hotel public areas, Omni provides “free high-speed in

all public areas. . .” for “member[s] of [Omni’s] Select Guest loyalty program.”


around its non-public areas and meeting rooms at the Omni Severin Hotel, Omni



and around its guest rooms at the Omni Severin Hotel, Omni provides free high-




Omni Jacksonville Hotel

215. Omni owns the Omni Jacksonville Hotel, which is a hotel facility

located at 245 Water Street, Jacksonville, FL 32202.

216. The Omni Jacksonville Hotel has 354 guest rooms, including a number

of suites.

217. The Omni Jacksonville Hotel also includes 15 conference rooms and




and around the Omni Jacksonville Hotel public areas, Omni provides “free high-


program.”

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around its non-public areas and meeting rooms at the Omni Jacksonville Hotel,



and around its guest rooms at the Omni Jacksonville Hotel, Omni provides free

high-speed for members of its Select Guest loyalty program.

Omni Nashville Hotel

221. Omni owns the Omni Nashville Hotel, which is a hotel facility located

at 250 5th Ave. South, Nashville, TN 37203.

222. The Omni Nashville Hotel has 800 guest rooms, including a number of

suites.

223. The Omni Nashville Hotel also includes a number of conference

rooms and ballrooms, a collective 80,000 square feet of meeting space used to host


functions.


and around the Omni Nashville Hotel public areas, Omni provides “free high-speed



around its non-public areas and meeting rooms at the Omni Nashville Hotel, Omni



and around its guest rooms at the Omni Nashville Hotel, Omni provides free high-




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Omni New Haven Hotel at Yale

227. Omni owns the Omni New Haven Hotel at Yale, which is a hotel

facility located at 250 5th Ave. South, Nashville, TN 37203.

228. The Omni New Haven Hotel at Yale has a number of guest rooms,


229. The Omni New Haven Hotel at Yale also includes 19 conference

rooms and one ballroom, a collective 22,000 square feet of meeting space used to

host events ranging from small board meetings to wedding receptions to major sales

functions.


and around the Omni New Haven Hotel at Yale public areas, Omni provides “free


program.”


around its non-public areas and meeting rooms at the Omni New Haven Hotel at

Yale, Omni offers access “for a nominal charge.”


and around its guest rooms at the Omni New Haven Hotel at Yale, Omni provides




Omni Royal Crescent Hotel

233. Omni owns the Omni Royal Crescent Hotel, which is a hotel facility

located at 535 Gravier Street, New Orleans, LA 70130.

234. The Omni Royal Crescent Hotel has 97 guest rooms.

235. The Omni Royal Crescent Hotel also includes 2 conference rooms, a

collective 596 square feet of meeting space used to host events ranging from small

board meetings to wedding receptions to sales functions.

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and around the Omni Royal Crescent Hotel public areas, Omni provides “free high-


program.”


around its non-public areas and meeting rooms at the Omni Royal Crescent Hotel,


Omni Royal Orleans

238. Omni owns the Omni Royal Orleans, which is a hotel facility located

at 621 St. Louis St., New Orleans, LA 70140.

239. The Omni Royal Orleans has 345 guest rooms, including a number of

suites.

240. The Omni Royal Orleans also includes 17 conference rooms and one




and around the Omni Royal Orleans public areas, Omni provides “free high-speed



around its non-public areas and meeting rooms at the Omni Royal Orleans, Omni



and around its guest rooms at the Omni Royal Orleans, Omni provides free high-




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Omni Berkshire Place

244. Omni owns the Omni Berkshire Place, which is a hotel facility located

at 21 E. 52nd St. at Madison Ave., New York, NY.

245. The Omni Berkshire Place has 396 guest rooms, including a number of

suites.

246. The Omni Berkshire Place also includes 11 conference rooms, a




and around the Omni Berkshire Place public areas, Omni provides “free high-speed



around its non-public areas and meeting rooms at the Omni Berkshire Place, Omni



and around its guest rooms at the Omni Berkshire Place, Omni provides free high-




Omni Hotel at Independence Park

250. Omni owns the Omni Hotel at Independence Park, which is a hotel

facility located at 401 Chestnut St., Philadelphia, PA 19106.

251. The Omni Hotel at Independence Park has 150 guest rooms, including

a number of suites.

252. The Omni Hotel at Independence Park also includes 4 conference



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and around the Omni Hotel at Independence Park public areas, Omni provides “free


program.”


around its non-public areas and meeting rooms at the Omni Hotel at Independence

Park, Omni offers access “for a nominal charge.”


and around its guest rooms at the Omni Nashville Hotel, Omni provides free high-

speed for members of its Select Guest loyalty program.

Omni William Penn Hotel

256. Omni owns the Omni William Penn Hotel, which is a hotel facility

located at 530 William Penn Place, Pittsburgh, PA 15219.

257. The Omni William Penn Hotel has 597 guest rooms, including a

number of suites.

258. The Omni William Penn Hotel also includes 38 conference rooms, a




and around the Omni William Penn Hotel public areas, Omni provides “free high-


program.”


around its non-public areas and meeting rooms at the Omni William Penn Hotel,



and around its guest rooms at the Omni William Penn Hotel, Omni provides free


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Omni Providence Hotel

262. Omni owns the Omni Providence Hotel, which is a hotel facility

located at One West Exchange St., Providence, RI 02903.

263. The Omni Providence Hotel has 564 guest rooms, including 28 suites.

264. The Omni Providence Hotel also includes 20 conference rooms and




and around the Omni Providence Hotel public areas, Omni provides “free high-


program.”


around its non-public areas and meeting rooms at the Omni Providence Hotel,



and around its guest rooms at the Omni Providence Hotel, Omni provides free high-




Omni Richmond Hotel

268. Omni owns the Omni Richmond Hotel, which is a hotel facility

located at 100 South 12th St., Richmond, VA 23219.

269. The Omni Richmond Hotel has 361 guest rooms, including a number

of suites.

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270. The Omni Richmond Hotel also includes 14 conference rooms and one




and around the Omni Richmond Hotel public areas, Omni provides “free high-


program.”


around its non-public areas and meeting rooms at the Omni Richmond Hotel, Omni



and around its guest rooms at the Omni Richmond Hotel, Omni provides free high-




Omni Majestic Hotel

274. Omni owns the Omni Majestic Hotel, which is a hotel facility located

at 1019 Pine St., St. Louis, MO 63101.

275. The Omni Majestic Hotel has a number of guest rooms, including a

number of suites.

276. The Omni Majestic Hotel also includes 4 conference rooms and one




and around the Omni Majestic Hotel public areas, Omni provides “free high-speed


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around its non-public areas and meeting rooms at the Omni Majestic Hotel, Omni



and around its guest rooms at the Omni Majestic Hotel, Omni provides free high-




Omni Shoreham Hotel

280. Omni owns the Omni Shoreham Hotel, which is a hotel facility located

at 2500 Calvert St. NW, Washington, DC 20008.

281. The Omni Shoreham Hotel has 832 guest rooms, including a number

of suites.

282. The Omni Shoreham Hotel also includes 24 conference rooms and 7

ballrooms, a collective 100,000 square feet of meeting space used to host events



and around the Omni Shoreham Hotel public areas, Omni provides “free high-speed



around its non-public areas and meeting rooms at the Omni Shoreham Hotel, Omni



and around its guest rooms at the Omni Shoreham Hotel, Omni provides free high-




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OMNI RESORTS

286. Omni owns at least twelve resort properties in the United States.

Omni La Costa Resort & Spa

287. Omni owns the Omni La Costa Resort & Spa, which is a resort facility

located at 2100 Costa Del Mar Road, San Diego, CA 92009.

288. The Omni La Costa Resort & Spa has 607 guest rooms, including 77

suites and 137 villas.

289. The Omni La Costa Resort & Spa also includes 46 conference rooms

and ballrooms, a collective 50,000 square feet of meeting space used to host events


Omni displays on its website “High-speed wireless Internet access” at the Omni La

Costa Resort & Spa.

290. Omni displays on its website “High-speed wireless Internet access” at

the Omni La Costa Resort & Spa.

Omni Rancho Las Palmas Resort and Spa

291. Omni owns the Omni Rancho Las Palmas Resort and Spa, which is a

resort facility located at 41-000 Bob Hope Dr., Palm Springs, CA 92270.

292. The Omni Rancho Las Palmas Resort and Spa has 444 guest rooms.

293. The Omni Rancho Las Palmas Resort and Spa also includes 28

conference rooms and 2 ballrooms, a collective 50,000 square feet of meeting space



294. Omni displays on its website “High-speed wireless Internet access” at

the Omni Rancho Las Palmas Resort and Spa.

Omni Amelia Island Plantation Resort and Villas of Amelia Island Plantation

295. Omni owns the Omni Amelia Island Plantation Resort, as associated

with the Villas of Amelia Island Plantation, which is a resort facility located at 39

Beach Lagoon, Amelia Island, FL 32034.

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296. The Omni Amelia Island Plantation Resort has 404 guest rooms,

including 27 suites and “numerous” multi-bedroom condos.

297. The Omni Amelia Island Plantation Resort also includes 30 conference



functions.

298. Omni displays on its website “WiFi access in-room and numerous on-

resort WiFi hot spots” at the Omni Amelia Island Plantation Resort.

Omni Grove Park Inn

299. Omni owns the Omni Grove Park Inn, which is a resort facility located

at 290 Macon Ave., Ashville, NC 28804.

300. The Omni Grove Park Inn has 513 guest rooms and 24 condominiums.

301. The Omni Grove Park Inn also includes 40 conference rooms and 2



302. Omni displays on its website “Free high-speed [WiFi] in all public

areas and in your guest room. Wi-fi access in non-public areas such as meeting

rooms is available for a nominal charge” at the Omni Grove Park Inn.

Omni Barton Creek Resort & Spa

303. Omni owns the Omni Barton Creek Resort & Spa, which is a resort

facility located at 8212 Barton Club Dr., Austin, TX 78735.

304. The Omni Barton Creek Resort & Spa has 309 guest rooms.

305. The Omni Barton Creek Resort & Spa also includes 27 conference



306. Omni displays on its website “High-speed wireless and wired internet

access” at the Omni Barton Creek Resort & Spa.

Omni Bedford Springs Resort

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307. Omni owns the Omni Bedford Springs Resort, which is a resort facility

located at 2138 Business 220, Bedford, PA 15522.

308. The Omni Bedford Springs Resort has 216 guest rooms.

309. The Omni Bedford Springs Resort also includes 13 conference rooms,

a collective 20,000 square feet of meeting space used to host events ranging from


310. Omni displays on its website “High-speed wireless Internet throughout

resort” and “in-room high-speed internet” at the Omni Bedford Springs Resort.

Omni Bretton Arms at Mount Washington

311. Omni owns the Omni Bretton Arms at Mount Washington, which is a

resort facility located at 173 Mount Washington Road, Bretton Woods, NH 03575.

312. The Omni Bretton Arms at Mount Washington has 34 guest rooms.

313. The Omni Bretton Arms at Mount Washington also includes 12

conference rooms and ballrooms, a collective 15,000 square feet of meeting space



314. Omni displays on its website “WiFi available” at the Omni Bretton

Arms at Mount Washington.

Omni Mount Washington Resort

315. Omni owns the Omni Mount Washington Resort, which is a resort

facility located at 310 Mount Washington Hotel Road, Bretton Woods, NH 03575.

316. The Omni Mount Washington Resort has 200 guest rooms, including

“numerous” multi-bedroom condos.

317. The Omni Mount Washington Resort also includes 15 conference



functions.

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318. Omni displays on its website “High-speed wireless Internet in-room

and numerous on-resort WiFi hot spots” at the Omni Mount Washington Resort.

Omni Hilton Head Oceanfront Resort

319. Omni owns the Omni Hilton Head Oceanfront Resort, which is a resort

facility located at 23 Ocean Land, Hilton Head, SC 29928.

320. The Omni Hilton Head Oceanfront Resort has 343 guest suites.

321. The Omni Hilton Head Oceanfront Resort also includes 12 conference



322. Omni displays on its website “High-speed wireless Internet access

available in public areas” and “As a member of our Select Guest loyalty program,

you will receive free high-speed in all public areas and in your guest room. Wi-fi

access in non-public areas such as meeting rooms is offered for a nominal charge”

at the Omni Hilton Head Oceanfront Resort.

The Omni Homestead Resort

323. Omni owns the Omni Homestead Resort, which is a resort facility

located at 7696 Sam Snead Highway, Hot Springs, VA 24445.

324. The Omni Homestead Resort has 483 guest rooms.

325. The Omni Homestead Resort also includes 26 conference rooms and 2



326. Omni displays on its website “High-speed wireless access throughout

resort” at the Omni Homestead Resort.

Omni Orlando Resort at ChampionsGate

327. Omni owns the Omni Orlando Resort at ChampionsGate, which is a

resort facility located at 1500 Masters Blvd., ChampionsGate, FL 33895.

328. The Omni Orlando Resort at ChampionsGate has 720 guest rooms,

including numerous villas.

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329. The Omni Orlando Resort at ChampionsGate also includes 46

conference rooms and ballrooms, a collective 128,800 square feet of meeting space



330. Omni displays on its website “As a member of our Select Guest

loyalty program, you will receive free high-speed in all public areas and in your

guest room. Wi-fi access in non-public areas such as meeting rooms is offered for a

nominal charge” at the Omni Orlando Resort at ChampionsGate.

Omni Tucson National Resort

331. Omni owns the Omni Tucson National Resort, which is a resort

facility located at 2727 West Club Dr., Tucson, AZ 85742.

332. The Omni Tucson National Resort has 404 guest rooms, including 23

multi-bedroom “haciendas.”

333. The Omni Tucson National Resort also includes 8 conference rooms, a



334. Omni displays on its website “As a member of our Select Guest

loyalty program, you will receive free high-speed in all public areas and in your

guest room. Wi-fi access in non-public areas such as meeting rooms is offered for a

nominal charge” at the Omni Tucson National Resort.

CLAIM I: INFRINGEMENT OF THE ’348 PATENT

335. Plaintiff alleges and incorporates by reference paragraphs 1-334 of this

Complaint as if fully set forth herein.

336. Plaintiff is the sole holder of all substantial rights to the ’348 patent.

337. By owning, operating, and managing hotels and resorts in a way that

includes maintaining multiple, overlapping wireless networks with differing levels

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of access as detailed above, Defendants have acted jointly and severally to directly

infringe one or more claims of the ’348 patent, including but not limited to Claim 4.

338. Defendants’ infringement is ongoing.

339. Omni Hotels Corporation, Omni Hotels Management Corporation, and

the individual Omni hotels and resorts have not taken or been granted a license to

the ’348 patent.

340. Plaintiff Lone Star WiFi has been, and continues to be, damaged by

Defendants’ infringement.

CLAIM II: INFRINGEMENT OF THE ’286 PATENT




343. By owning, operating, and managing hotels and resorts in a way that







the ’286 patent.



CLAIM III: INFRINGEMENT OF THE ’935 PATENT




349. By owning, operating, and managing, hotels and resorts in a way that


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the ’935 patent.



JURY DEMAND

353. Plaintiff demands a trial by jury on all issues.

REQUEST FOR RELIEF

WHEREFORE, Plaintiff Lone Star WiFi respectfully requests the following

relief:

A. A judgment holding the Defendants liable for infringement of the

Patents-in-Suit asserted against them;

B. An accounting for damages resulting from the Defendants’

infringement of the Patents-in-Suit asserted against them, together with pre-

judgment and post-judgment interest;

C. A judgment holding this Action to be an exceptional case, and an

award to Plaintiff for its attorney’s fees and costs pursuant to 35 U.S.C. § 285; and

D. Such other and further relief as this Court deems just and proper.

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DATED: April 4, 2014

NELSON BUMGARDNER CASTO, P.C.

By:/S/ Jaime K. Olin Jaime K. Olin (SBN 243139) Brent N. Bumgardner (Pro Hac pending) Edward R. Nelson, III (Pro Hac pending) Jonathan H. Rastegar (Pro Hac pending)

Attorneys for Plaintiff, LONE STAR WIFI LLC

Documents

Lone Star Wifi v. Omni Hotels et. al