Lone Star WiFi v. Omni Hotel Et. Al.

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION
LONE STAR WIFI LLC, Plaintiff, v. OMNI HOTEL CORPORATION AND OMNI HOTELS MANAGEMENT CORPORATION, Defendant.
CIVIL ACTION NO. 6:14-cv-33 JURY TRIAL DEMANDED
PLAINTIFFS ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT 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 714, Tyler, TX 75702. 2. Omni Hotel Corporation is a Delaware corporation with its principal place of
business at 4001 Maple Ave., Dallas, Texas 75219. Omni Hotel Corporation can be served through Corporation Service Company, 211 E. 7th St., Suite 620, Austin, Texas 78701. 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 600 East Las Colinas Blvd., Suite 1900, Irving, Texas 75039. 4. Omni Hotel Corporation and Omni Hotels Management Corporation are
collectively referred to herein as Omni.

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LONE STAR WIFIS COMPLAINT FOR PATENT INFRINGEMENT
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. Defendants are subject to this Courts specific and general personal jurisdiction
pursuant to due process and/or the Texas Long Arm Statute. Defendants are subject to personal jurisdiction in the State of Texas and this district at least because, on information and belief, they regularly and purposefully advertise, solicit, and transact substantial business related to the infringements alleged herein in the State of Texas and this district. Defendants are subject to general jurisdiction in the State of Texas and this district at least because, on information and belief, they regularly do or solicit business, engage in other persistent courses of conduct, and/or derive substantial revenue from goods and services provided to persons or entities in the State of Texas and this district. 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. 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.
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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. Harriss 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. 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.
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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. 23. Omni has cited complimentary results from the J.D. Power annual survey. 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.
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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 todays 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 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.
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30.
Another example of a national service reporting data regarding the hotel industry
is TripAdvisor. TripAdvisor claims to be the worlds 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 1000 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. TripAdvisors 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 during June 2012, while thirty percent of U.S. accommodation owners reported their businesses were extremely profitable or very profitable over that period.
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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 itselfhave also noticed the trend themselves. 42. 43. Omni was one of the first hotel chains to offer free WiFi to guests. 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. Marriott CEO J.W. Bill Marriott Jr. commented that, Its a huge problem.
Everyone wants to talk in the room and they want to download everything they can. Its getting
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to be quite a challenge. 46. Richard Solomons, CEO of InterContinental Hotels Group, agreed that We all
see it as an issue. Its one of the big dissatisfiers that you see in a lot of hotels. 47. Carlson CEO Hubert Joly responded that, Free Internet is the greatest demand in
terms of amenities of the travelers. Its 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 its free, youd 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 Kathleen Taylor responded that Technology is one of the leading edge issues for consumers in all segments. Its 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-SurveyReveals-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
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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. 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,
Starwoods 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 Apples
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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 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 cant not have full connectivity for your attendees or they wont come. 63. Moreover, in an effort to keep guests and meeting attendeesand their
associated spending on drinks, food, and other incidentalswithin 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 its 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. Its 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, theyre all over the lobby, and theyre coming back to the hotel and using the lobby for a drink afterward. Defendants Own and/or Manage Omni Hotels and Resorts
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65. 66.
Omni is an increasingly visible, well-known hotel chain. Omni owns and/or manages 50 hotels and resorts in North America, 46 of which
are located in the United States. 67. Omnis 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. 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. Omnis 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 Omnis Hotels and Resorts Infringe the Patents-in-Suit.
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73.
Upon information and belief, all of Omnis 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 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. 80. 81. 82. Such networks may include lobby networks. Such networks may include guest networks. Such networks may include conference room networks. Such networks may include private, secure networks.
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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 Dallas Hotel at Park West 85. Omni owns the Omni Dallas Hotel at Park West, which is a hotel facility located
at 1590 LBJ Freeway, Dallas, TX 75234, within one hundred miles of this judicial District. 86. suites. 87. The Omni Dallas Hotel at Park West also includes 8 conference suites and 2 The Omni Dallas Hotel at Park West has 337 guest rooms, including a number of
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. 88. As Omni displays on its website, for access to the wireless network in and
around the Omni Dallas Hotel at Park West public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] 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 Dallas Hotel at Park West, Omni offers access for a nominal charge. 90. As Omni displays on its website, for access to the wireless network in 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.
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Omni Mandalay Hotel at Las Colinas 91. Omni owns the Omni Mandalay Hotel at Las Colinas, which is a hotel facility
located at 221 E. Las Colinas Blvd., Dallas, TX 75039, within one hundred miles of this judicial District. 92. The Omni Mandalay Hotel at Las Colinas has 421 guest rooms, including a
number of suites. 93. 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. 94. As Omni displays on its website, for access to the wireless network in and
around the Omni Mandalay Hotel at Las Colinas public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 95. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Mandalay Hotel at Las Colinas, Omni offers access for a nominal charge. 96. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Mandalay Hotel at Las Colinas , Omni provides free highspeed 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 97. Omni owns the Omni Dallas Hotel, which is a hotel facility located at 555 S.
Lamar, Dallas, TX 75202, within one hundred miles of this judicial District.
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98. 99.
The Omni Dallas Hotel has 1001 guest rooms, including 67 suites. 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. 100. As Omni displays on its website, for access to the wireless network in 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 [Omnis] Select Guest loyalty program and additional bandwidth may be purchased at a discounted rate for our Select Guest loyalty members. 101. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Dallas Hotel, Omni offers access for a nominal charge. 102. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Dallas 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 Fort Worth Hotel 103. Omni owns the Omni Fort Worth Hotel, which is a hotel facility located at 1300
Houston Street, Fort Worth, TX 76102, within one hundred miles of this judicial District. 104. The Omni Fort Worth Hotel has 614 guest rooms, including a number of suites.
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105.
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. 106. As Omni displays on its website, for access to the wireless network in and
around the Omni Fort Worth Hotel public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 107. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Fort Worth Hotel , Omni offers access for a nominal charge. 108. As Omni displays on its website, for access to the wireless network in 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 109. Omni owns the Omni Houston Hotel, which is a hotel facility located at Four
Riverway, Houston, TX 77056. 110. 111. The Omni Houston Hotel has 378 guest rooms, including 33 suites. The Omni Houston Hotel also includes 12 conference rooms and one
around the Omni Houston Hotel public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program.
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113.
As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Houston Hotel , Omni offers access for a nominal charge. 114. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Houston 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 Houston Hotel at Westside 115. Omni owns the Omni Houston Hotel at Westside, which is a hotel facility located
at 13210 Katy Freeway, Houston, TX 77079. 116. of suites. 117. The Omni Houston Hotel at Westside also includes 25 conference rooms and one The Omni Houston Hotel at Westside has 400 guest rooms, including a number
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. 118. As Omni displays on its website, for access to the wireless network in and
around the Omni Houston Hotel at Westside public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 119. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Houston Hotel at Westside, Omni offers access for a nominal charge. 120. As Omni displays on its website, for access to the wireless network in and
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around its guest rooms at the Omni Houston Hotel at Westside, 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 Austin Hotel Downtown 121. Omni owns the Omni Austin Hotel Downtown, which is a hotel facility located at
700 San Jacinto at 8th St., Austin, TX 78701. 122. 123. The Omni Austin Hotel Downtown has 392 guest rooms, including 91 suites. The Omni Austin Hotel Downtown also includes 16 conference rooms and
around the Omni Austin Hotel Downtown public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 125. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Austin Hotel Downtown, Omni offers access for a nominal charge. 126. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Austin Hotel Downtown, 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 Austin Hotel at Southpark
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127.
Omni owns the Omni Austin Hotel at Southpark, which is a hotel facility located
at 4140 Governors Row, Austin, TX 78744. 128. suites. 129. The Omni Austin Hotel at Southpark also includes 13 conference rooms, a The Omni Austin Hotel at Southpark has 312 guest rooms, including a number of
collective 13,677 square feet of meeting space used to host events ranging from small board meetings to wedding receptions to major sales functions. 130. As Omni displays on its website, for access to the wireless network in 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 [Omnis] Select Guest loyalty program, with faster download speeds of up to 6 MB premium Wifi upgrade at $4.95 per 24 hours [] now available. 131. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Austin Hotel at Southpark, Omni offers access for a nominal charge. 132. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Austin Hotel at Southpark , 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 or $14.95 per day plus tax for our 6 MB service. Omni Corpus Christi Hotel 133. Omni owns the Omni Corpus Christi Hotel, which is a hotel facility located at 900
North Shoreline Blvd., Corpus Christi, TX.

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134. suites. 135.
The Omni Corpus Christi Hotel has 475 guest rooms, including a number of
The Omni Corpus Christi Hotel also includes 11 conference rooms and one
around the Omni Corpus Christi Hotel public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 137. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Corpus Christi Hotel, Omni offers access for a nominal charge. 138. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Corpus Christi 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 La Mansion del Rio 139. Omni owns the Omni La Mansion del Rio, which is a hotel facility located at 112
College St., San Antonio, TX 78205. 140. suites. 141. The Omni La Mansion del Rio also includes 16 conference rooms and one The Omni La Mansion del Rio has 338 guest rooms, including a number of
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around the Omni La Mansion del Rio public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 143. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni La Mansion del Rio, Omni offers access for a nominal charge. 144. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni La Mansion del Rio, 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 Antonio Hotel at the Colonnade 145. Omni owns the Omni San Antonio Hotel at the Colonnade, which is a hotel
facility located at 9821 Colonnade Blvd., San Antonio, TX 78230. 146. The Omni San Antonio Hotel at the Colonnade has 326 guest rooms, including a
number of suites. 147. 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. 148. As Omni displays on its website, for access to the wireless network in and
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around the Omni San Antonio Hotel at the Colonnade public areas, Omni provides free highspeed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 149. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni San Antonio Hotel at the Colonnade, Omni offers access for a nominal charge. 150. As Omni displays on its website, for access to the wireless network in 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 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 151. Omni owns the Mokara Hotel & Spa, which is a hotel facility located at 212 West
Crockett St., San Antonio, TX 78205. 152. suites. 153. The Mokara Hotel & Spa also includes 6 conference rooms, a collective 3726 The Mokara Hotel & Spa has a number of guest rooms, including a number of
around the Mokara Hotel & Spa guest rooms, Omni provides complimentary in-room wireless Internet access. Omni Hotel at CNN Center
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155.
Omni owns the Omni Hotel at CNN Center, which is a hotel facility located at
100 CNN Center, Atlanta, GA 30303. 156. Omni owns the Omni Hotel at CNN Center has 1070 guest rooms, including a
number of suites. 157. The Omni Hotel at CNN Center also includes 45 conference rooms and
around the Omni Hotel at CNN Center public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 159. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Hotel at CNN Center, Omni offers access for a nominal charge. 160. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Hotel at CNN Center, 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 Parker House 161. Omni owns the Omni Parker House, which is a hotel facility located at 60 School
Street, Boston, MA 02108. 162. The Omni Parker House has 551 guest rooms, including a number of suites.
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163.
The Omni Parker House also includes 18 conference rooms and one ballroom, a
around the Omni Parker House public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 165. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Parker House, Omni offers access for a nominal charge. 166. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Parker House, 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 Charlotte Hotel 167. Omni owns the Omni Charlotte Hotel, which is a hotel facility located at 132 E.
Trade St., Charlotte, NC 28202. 168. 169. The Omni Charlotte Hotel has 374 guest rooms, including a number of suites. The Omni Charlotte Hotel also includes 13 conference rooms and one ballroom, a
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around the Omni Charlotte Hotel public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 171. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Charlotte Hotel, Omni offers access for a nominal charge. 172. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Charlotte 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 Charlottesville Hotel 173. Omni owns the Omni Charlottesville Hotel, which is a hotel facility located at 212
Ridge McIntire Road, Charlottesville, VA 22903. 174. suites. 175. The Omni Charlottesville Hotel also includes 16 conference rooms and one The Omni Charlottesville Hotel has 208 guest rooms, including a number of
around the Omni Charlottesville Hotel public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program.
25
177.
public areas and meeting rooms at the Omni Charlottesville Hotel, Omni offers access for a nominal charge. 178. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Charlottesville 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 Chicago Hotel 179. Omni owns the Omni Chicago Hotel, which is a hotel facility located at 676
North Michigan Ave., Chicago, IL 60611. 180. 181. The Omni Chicago Hotel has 347 guest suites. The Omni Chicago Hotel also includes 9 conference rooms, a collective 8000
around the Omni Chicago Hotel public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 183. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Chicago Hotel, Omni offers access for a nominal charge. 184. As Omni displays on its website, for access to the wireless network in and
26
around its guest rooms at the Omni Chicago 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 Interlocken Hotel 185. Omni owns the Omni Interlocken Hotel, which is a hotel facility located at 500
Interlocken Blvd., Denver, CO 80021. 186. 187. The Omni Interlocken Hotel has 390 guest rooms, including a number of suites. The Omni Interlocken Hotel also includes 14 conference rooms and one
around the Omni Interlocken Hotel public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 189. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Interlocken Hotel, Omni offers access for a nominal charge. 190. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Interlocken 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 Severin Hotel
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191.
Omni owns the Omni Severin Hotel, which is a hotel facility located at 40 W.
Jackson Place, Indianapolis, IN 46225. 192. 193. The Omni Severin Hotel has 424 guest rooms, including a number of suites. The Omni Severin Hotel also includes 17 conference rooms and one ballroom, a
around the Omni Severin Hotel public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 195. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Severin Hotel, Omni offers access for a nominal charge. 196. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Severin 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 Jacksonville Hotel 197. Omni owns the Omni Jacksonville Hotel, which is a hotel facility located at 245
Water Street, Jacksonville, FL 32202. 198. The Omni Jacksonville Hotel has 354 guest rooms, including a number of suites.
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199.
The Omni Jacksonville Hotel also includes 15 conference rooms and one
around the Omni Jacksonville Hotel public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 201. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Jacksonville Hotel, Omni offers access for a nominal charge. 202. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Jacksonville Hotel, Omni provides free high-speed for members of its Select Guest loyalty program. Omni Los Angeles Hotel at California Plaza 203. 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. 204. The Omni Los Angeles Hotel at California Plaza has 453 guest rooms, including
a number of suites. 205. 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. 206. As Omni displays on its website, for access to the wireless network in and
around the Omni Los Angeles Hotel at California Plaza public areas, Omni provides free highspeed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program.
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207.
public areas and meeting rooms at the Omni Los Angeles Hotel at California Plaza, Omni offers access for a nominal charge. 208. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Los Angeles Hotel at California Plaza, 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 Nashville Hotel 209. Omni owns the Omni Nashville Hotel, which is a hotel facility located at 250 5th
Ave. South, Nashville, TN 37203. 210. 211. The Omni Nashville Hotel has 800 guest rooms, including a number of suites. The Omni Nashville Hotel also includes a number of conference rooms and
around the Omni Nashville Hotel public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 213. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Nashville Hotel, Omni offers access for a nominal charge. 214. As Omni displays on its website, for access to the wireless network in and
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around its guest rooms at the Omni Nashville 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 New Haven Hotel at Yale 215. Omni owns the Omni New Haven Hotel at Yale, which is a hotel facility located
at 250 5th Ave. South, Nashville, TN 37203. 216. The Omni New Haven Hotel at Yale has a number of guest rooms, including a
number of suites. 217. The Omni New Haven Hotel at Yale also includes 19 conference rooms and one
around the Omni New Haven Hotel at Yale public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 219. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni New Haven Hotel at Yale, Omni offers access for a nominal charge. 220. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni New Haven Hotel at Yale, 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.
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Omni Royal Crescent Hotel 221. Omni owns the Omni Royal Crescent Hotel, which is a hotel facility located at
535 Gravier Street, New Orleans, LA 70130. 222. 223. The Omni Royal Crescent Hotel has 97 guest rooms. 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 major sales functions. 224. As Omni displays on its website, for access to the wireless network in and
around the Omni Royal Crescent Hotel public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 225. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Royal Crescent Hotel, Omni offers access for a nominal charge. Omni Royal Orleans 226. Omni owns the Omni Royal Orleans, which is a hotel facility located at 621 St.
Louis St., New Orleans, LA 70140. 227. 228. The Omni Royal Orleans has 345 guest rooms, including a number of suites. The Omni Royal Orleans also includes 17 conference rooms and one ballroom, a
around the Omni Royal Orleans public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program.
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230.
public areas and meeting rooms at the Omni Royal Orleans, Omni offers access for a nominal charge. 231. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Royal Orleans, 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 Berkshire Place 232. Omni owns the Omni Berkshire Place, which is a hotel facility located at 21 E.
52nd St. at Madison Ave., New York, NY. 233. 234. The Omni Berkshire Place has 396 guest rooms, including a number of suites. The Omni Berkshire Place also includes 11 conference rooms, a collective 7000
around the Omni Berkshire Place public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 236. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Berkshire Place, Omni offers access for a nominal charge. 237. As Omni displays on its website, for access to the wireless network in and
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around its guest rooms at the Omni Berkshire Place, 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. Omni Hotel at Independence Park 238. Omni owns the Omni Hotel at Independence Park, which is a hotel facility located
at 401 Chestnut St., Philadelphia, PA 19106. 239. of suites. 240. The Omni Hotel at Independence Park also includes 4 conference rooms, a The Omni Hotel at Independence Park has 150 guest rooms, including a number
collective 3500 square feet of meeting space used to host events ranging from small board meetings to wedding receptions to major sales functions. 241. As Omni displays on its website, for access to the wireless network in and
around the Omni Hotel at Independence Park public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 242. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Hotel at Independence Park, Omni offers access for a nominal charge. 243. As Omni displays on its website, for access to the wireless network in 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
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244.
Omni owns the Omni William Penn Hotel, which is a hotel facility located at 530
William Penn Place, Pittsburgh, PA 15219. 245. suites. 246. The Omni William Penn Hotel also includes 38 conference rooms, a collective The Omni William Penn Hotel has 597 guest rooms, including a number of
52,000 square feet of meeting space used to host events ranging from small board meetings to wedding receptions to major sales functions. 247. As Omni displays on its website, for access to the wireless network in and
around the Omni William Penn Hotel public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 248. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni William Penn Hotel, Omni offers access for a nominal charge. 249. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni William Penn 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 Providence Hotel 250. Omni owns the Omni Providence Hotel, which is a hotel facility located at One
West Exchange St., Providence, RI 02903. 251. The Omni Providence Hotel has 564 guest rooms, including 28 suites.
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252.
The Omni Providence Hotel also includes 20 conference rooms and one ballroom,
a collective 22,877 square feet of meeting space used to host events ranging from small board meetings to wedding receptions to major sales functions. 253. As Omni displays on its website, for access to the wireless network in and
around the Omni Providence Hotel public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 254. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Providence Hotel, Omni offers access for a nominal charge. 255. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Providence 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 Richmond Hotel 256. Omni owns the Omni Richmond Hotel, which is a hotel facility located at 100
South 12th St., Richmond, VA 23219. 257. 258. The Omni Richmond Hotel has 361 guest rooms, including a number of suites. The Omni Richmond Hotel also includes 14 conference rooms and one ballroom,
36
around the Omni Richmond Hotel public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 260. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Richmond Hotel, Omni offers access for a nominal charge. 261. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Richmond 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 San Diego Hotel 262. Omni owns the Omni San Diego Hotel, which is a hotel facility located at 675 L
Street, San Diego, CA 92101. 263. 264. The Omni San Diego Hotel has 511 guest rooms, including a number of suites. The Omni San Diego Hotel also includes 21 conference rooms and one ballroom,
around the Omni San Diego Hotel public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 266. 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.
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267.
As Omni displays on its website, for access to the wireless network in 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 San Francisco Hotel 268. Omni owns the Omni San Francisco Hotel, which is a hotel facility located at 500
California Street, San Francisco, CA 94104. 269. suites. 270. The Omni San Francisco Hotel also includes 7 conference rooms and one The Omni San Francisco Hotel has 362 guest rooms, including a number of
around the Omni San Francisco Hotel public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 272. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni San Francisco Hotel, Omni offers access for a nominal charge. 273. As Omni displays on its website, for access to the wireless network in 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
38
$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 Majestic Hotel 274. Omni owns the Omni Majestic Hotel, which is a hotel facility located at 1019
Pine St., St. Louis, MO 63101. 275. suites. 276. The Omni Majestic Hotel also includes 4 conference rooms and one ballroom, a The Omni Majestic Hotel has a number of guest rooms, including a number of
collective 2755 square feet of meeting space used to host events ranging from small board meetings to wedding receptions to major sales functions. 277. As Omni displays on its website, for access to the wireless network in and
around the Omni Majestic Hotel public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 278. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Majestic Hotel, Omni offers access for a nominal charge. 279. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Majestic 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 Shoreham Hotel
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280.
Omni owns the Omni Shoreham Hotel, which is a hotel facility located at 2500
Calvert St. NW, Washington, DC 20008. 281. 282. The Omni Shoreham Hotel has 832 guest rooms, including a number of suites. The Omni Shoreham Hotel also includes 24 conference rooms and 7 ballrooms, a
around the Omni Shoreham Hotel public areas, Omni provides free high-speed in all public areas. . . for member[s] of [Omnis] Select Guest loyalty program. 284. As Omni displays on its website, for the wireless network in and around its non-
public areas and meeting rooms at the Omni Shoreham Hotel, Omni offers access for a nominal charge. 285. As Omni displays on its website, for access to the wireless network in and
around its guest rooms at the Omni Shoreham 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 RESORTS 286. Omni owns at least twelve resort properties in the United States.
Omni Amelia Island Plantation Resort and Villas of Amelia Island Plantation 287. 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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288.
The Omni Amelia Island Plantation Resort has 404 guest rooms, including 27
suites and numerous multi-bedroom condos. 289. The Omni Amelia Island Plantation Resort also includes 30 conference rooms and
ballrooms, a collective 80,000 square feet of meeting space used to host events ranging from small board meetings to wedding receptions to major sales functions. 290. 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 291. Omni owns the Omni Grove Park Inn, which is a resort facility located at 290
Macon Ave., Ashville, NC 28804. 292. 293. The Omni Grove Park Inn has 513 guest rooms and 24 condominiums. The Omni Grove Park Inn also includes 40 conference rooms and 2 ballrooms, a
collective 57,000 square feet of meeting space used to host events ranging from small board meetings to wedding receptions to major sales functions. 294. 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 295. Omni owns the Omni Barton Creek Resort & Spa, which is a resort facility
located at 8212 Barton Club Dr., Austin, TX 78735. 296. The Omni Barton Creek Resort & Spa has 309 guest rooms.
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297.
The Omni Barton Creek Resort & Spa also includes 27 conference rooms, 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. 298. Omni displays on its website High-speed wireless and wired internet access at
the Omni Barton Creek Resort & Spa. Omni Bedford Springs Resort 299. Omni owns the Omni Bedford Springs Resort, which is a resort facility located at
2138 Business 220, Bedford, PA 15522. 300. 301. The Omni Bedford Springs Resort has 216 guest rooms. 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 small board meetings to wedding receptions to major sales functions. 302. 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 303. Omni owns the Omni Bretton Arms at Mount Washington, which is a resort
facility located at 173 Mount Washington Road, Bretton Woods, NH 03575. 304. 305. The Omni Bretton Arms at Mount Washington has 34 guest rooms. The Omni Bretton Arms at Mount Washington also includes 12 conference rooms
and ballrooms, a collective 15,000 square feet of meeting space used to host events ranging from small board meetings to wedding receptions to major sales functions. 306. Omni displays on its website WiFi available at the Omni Bretton Arms at
Mount Washington.
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Omni Mount Washington Resort 307. Omni owns the Omni Mount Washington Resort, which is a resort facility located
at 310 Mount Washington Hotel Road, Bretton Woods, NH 03575. 308. The Omni Mount Washington Resort has 200 guest rooms, including numerous
multi-bedroom condos. 309. The Omni Mount Washington Resort also includes 15 conference rooms and
ballrooms, a collective 30,000 square feet of meeting space used to host events ranging from small board meetings to wedding receptions to major sales functions. 310. 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 311. Omni owns the Omni Hilton Head Oceanfront Resort, which is a resort facility
located at 23 Ocean Land, Hilton Head, SC 29928. 312. 313. The Omni Hilton Head Oceanfront Resort has 343 guest suites. The Omni Hilton Head Oceanfront Resort also includes 12 conference rooms, a
collective 15,000 square feet of meeting space used to host events ranging from small board meetings to wedding receptions to major sales functions. 314. 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 highspeed 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
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315.
Omni owns the Omni Homestead Resort, which is a resort facility located at 7696
Sam Snead Highway, Hot Springs, VA 24445. 316. 317. The Omni Homestead Resort has 483 guest rooms. The Omni Homestead Resort also includes 26 conference rooms and 2 ballrooms,
a collective 72,000 square feet of meeting space used to host events ranging from small board meetings to wedding receptions to major sales functions. 318. Omni displays on its website High-speed wireless access throughout resort at
the Omni Homestead Resort. Omni Orlando Resort at ChampionsGate 319. Omni owns the Omni Orlando Resort at ChampionsGate, which is a resort facility
located at 1500 Masters Blvd., ChampionsGate, FL 33895. 320. The Omni Orlando Resort at ChampionsGate has 720 guest rooms, including
numerous villas. 321. The Omni Orlando Resort at ChampionsGate also includes 46 conference rooms
and ballrooms, a collective 128,800 square feet of meeting space used to host events ranging from small board meetings to wedding receptions to major sales functions. 322. 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 nonpublic areas such as meeting rooms is offered for a nominal charge at the Omni Orlando Resort at ChampionsGate. Omni Rancho Las Palmas Resort and Spa 323. 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.

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324. 325.
The Omni Rancho Las Palmas Resort and Spa has 444 guest rooms. 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 used to host events ranging from small board meetings to wedding receptions to major sales functions. 326. Omni displays on its website High-speed wireless Internet access at the Omni
Rancho Las Palmas Resort and Spa. Omni La Costa Resort & Spa 327. Omni owns the Omni La Costa Resort & Spa, which is a resort facility located at
2100 Costa Del Mar Road, San Diego, CA 92009. 328. 137 villas. 329. The Omni La Costa Resort & Spa also includes 46 conference rooms and The Omni La Costa Resort & Spa has 607 guest rooms, including 77 suites and
ballrooms, a collective 50,000 square feet of meeting space used to host events ranging from small board meetings to wedding receptions to major sales functions. 330. Omni displays on its website High-speed wireless Internet access at the Omni
La Costa Resort & Spa. 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.
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333.
The Omni Tucson National Resort also includes 8 conference rooms, a collective
10,500 square feet of meeting space used to host events ranging from small board meetings to wedding receptions to major sales functions. 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 nonpublic 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 realleges and incorporates by reference paragraphs 1- 334 of this
Complaint as if fully set forth herein. 336. 337. Plaintiff is the sole holder of all substantial rights to the 348 patent. By owning, operating, and managing hotels and resorts in a way that includes
maintaining multiple, overlapping wireless networks with differing levels of access as detailed above, Defendants have acted jointly and severally to directly infringe one or more claims of the348 patent, including but not limited to Claim 4. 338. 339. Defendants infringement is ongoing. Omni Hotel 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. infringement. CLAIM II: INFRINGEMENT OF THE 286 PATENT 341. Plaintiff realleges and incorporates by reference paragraphs 1-340 of this Plaintiff Lone Star WiFi has been, and continues to be, damaged by Defendants
Complaint as if fully set forth herein.

46
342. 343.
Plaintiff is the sole holder of all substantial rights to the 286 patent. By owning, operating, and managing hotels and resorts in a way that includes
maintaining multiple, overlapping wireless networks with differing levels of access as detailed above, Defendants have acted jointly and severally to directly infringe one or more claims of the 286 patent, including but not limited to Claim 1. 344. 345. Defendants infringement is ongoing. Omni Hotel Corporation, Omni Hotels Management Corporation, and the
individual Omni hotels and resorts have not taken or been granted a license to the 286 patent. 346. infringement. CLAIM III: INFRINGEMENT OF THE 935 PATENT 347. Plaintiff realleges and incorporates by reference paragraphs 1-346 of this Plaintiff Lone Star WiFi has been, and continues to be, damaged by Defendants
Complaint as if fully set forth herein. 348. 349. Plaintiff is the sole holder of all substantial rights to the 935 patent. By owning, operating, and managing, hotels and resorts in a way that includes
maintaining multiple, overlapping wireless networks with differing levels of access as detailed above, Defendants have acted jointly and severally to directly infringe one or more claims of the 935 patent, including but not limited to Claim 1. 350. 351. Defendants infringement is ongoing. Omni Hotel Corporation, Omni Hotels Management Corporation, and the
individual Omni hotels and resorts have not taken or been granted a license to the 935 patent. 352. infringement.
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Plaintiff Lone Star WiFi has been, and continues to be, damaged by Defendants
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. b. A judgment holding the Defendants liable for infringement of the Patents-in-Suit asserted against them; An accounting for damages resulting from the Defendants infringement of the Patents-in-Suit asserted against them, together with pre-judgment and postjudgment interest; A judgment holding this Action to be an exceptional case, and an award to Plaintiff for its attorneys fees and costs pursuant to 35 U.S.C. 285; and Such other and further relief as this Court deems just and proper.
c. d.
Dated: January 21, 2014
Respectfully submitted, /s/ Brent Bumgardner by permission T. John Ward, Jr. Brent N. Bumgardner Lead Attorney Texas State Bar No. 00795272 Edward R. Nelson, III Texas State Bar No. 00797142 Jaime K. Olin Texas State Bar No. 24070363 Jonathan H. Rastegar Texas State Bar No. 24064043 NELSON BUMGARDNER CASTO, P.C. 3131 West 7th Street, Suite 300 Fort Worth, Texas 76107 Phone: (817) 377-9111 Fax: (817) 377-3485 bbumgardner@nbclaw.net enelson@nbclaw.net jolin@nbclaw.net jrastegar@nbclaw.net
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T. John Ward, Jr. Texas State Bar No. 00794818 T. John Ward State Bar No. 20848000 Wesley Hill Texas State Bar No. 24032294 Claire Abernathy Henry State Bar No. 24053063 WARD & SMITH LAW FIRM P.O. Box 1231 1127 Judson Road, Ste. 220 Longview, Texas 75601 (903) 757-6400 (phone) (903) 757-2323 (fax) jw@wsfirm.com tjw@wsfirm.com wh@wsfirm.com claire@wsfirm.com ATTORNEYS FOR PLAINTIFF LONE STAR WIFI LLC
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Lone Star WiFi v. Omni Hotel Et. Al.

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION

CIVIL ACTION NO. 6:14-cv-33 JURY TRIAL DEMANDED

collectively referred to herein as Omni.

the hospitality industry.

North Shoreline Blvd., Corpus Christi, TX.

134. suites. 135.

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

Complaint as if fully set forth herein.

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

Dated: January 21, 2014

LONE STAR WIFIS COMPLAINT FOR PATENT INFRINGEMENT

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