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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

GLOBAL WIRELESS SOLUTIONS LLC,

Plaintiff,

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

JURY 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 January 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) MOBI’s 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