Case 1:18-cv-00927-RBJ Document 28 Filed 06/13/18 USDC Colorado Page 1 of 20
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF COLORADO
`
`Civil Action No. 1:18-cv-00927-MJW
`
`REALTIME ADAPTIVE STREAMING LLC,
`
`
`
`Plaintiff,
`
`v.
`
`WOWZA MEDIA SYSTEMS, LLC
`
`Defendant.
`
`
`
`
`WOWZA’S ANSWER TO REALTIME ADAPTIVE STREAMING’S
`COMPLAINT FOR PATENT INFRINGEMENT
`
`
`Defendant Wowza Media Systems, LLC answers Realtime Adaptive Streaming, LLC’s
`
`Complaint (Dkt. No. 1) as follows. Wowza denies that it has infringed any claims of U.S. Patent
`
`Nos. 7,386,046, 8,934,535, 9,769,477, 8,634,462, and 9,578,298 (the “patents-in-suit”) and further
`
`denies that the patents-in-suit are valid. In addition, Wowza denies that Realtime is entitled to any
`
`relief whatsoever and denies any and all allegations not specifically and expressly admitted in this
`
`Answer.
`
`PARTIES1
`
`1.
`
`Wowza lacks sufficient information to form a belief as to the truth or falsity of the
`
`allegations in paragraph 1 of the Complaint and, on that basis, denies them.
`
`2.
`
`Wowza admits that it is a Delaware limited liability company with its principal place
`
`of business in Golden, Colorado. Wowza also admits that it maintains its headquarters at 523 Park
`
`Point Drive, Suite 300, Golden, Colorado 80401. Wowza admits that it offers products and/or
`
`
`1 To the extent Realtime intends the headings in its Complaint to constitute allegations, Wowza de-
`nies them. The headings in Wowza’s Answer do not constitute responses to them.
`
`

`

`Case 1:18-cv-00927-RBJ Document 28 Filed 06/13/18 USDC Colorado Page 2 of 20
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`services to customers and potential customers located in Colorado and in this District. And Wowza
`
`admits that its agent, Elliot Foster Jordan Miller, may be served with process at 523 Park Point
`
`Drive, Suite 300, Golden, Colorado 80401. Wowza denies the remaining allegations in paragraph 2
`
`of the Complaint.
`
`JURISDICTION AND VENUE
`
`3.
`
`Wowza admits that Realtime purports to allege an action for patent infringement
`
`arising under the patent laws of the United States and that this Court has subject matter jurisdiction
`
`pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`
`4.
`
`Wowza admits that this Court has personal jurisdiction over it. Wowza denies the
`
`remaining allegations in paragraph 4 of the Complaint.
`
`5.
`
`Wowza admits that venue is proper in this district under 28 U.S.C. § 1400(b). Wowza
`
`further admits that it is registered to do business in Colorado and has transacted business in the
`
`District of Colorado. Wowza denies the remaining allegations in paragraph 5 of the Complaint.
`
`THE PATENTS-IN-SUIT
`
`6.
`
` Wowza admits that Realtime alleges causes of action arising under 35 U.S.C. § 271
`
`but denies that it has committed any acts of patent infringement. Wowza denies the remaining
`
`allegations in paragraph 6 of the Complaint.
`
`7.
`
`Wowza admits that the document attached to the Complaint as Exhibit A purports
`
`to be a copy of U.S. Patent No. 7,386,046 (the ’046 Patent) and admits that Exhibit A bears on its
`
`face an issue date of June 10, 2008, and the title “Bandwidth Sensitive Data Compression and
`
`Decompression.” Wowza lacks sufficient information to form a belief as to the truth or falsity of the
`
`remaining allegations contained in paragraph 7 of the Complaint and, therefore, denies them.
`
`8.
`
`Wowza admits that the document attached to the Complaint as Exhibit B purports
`
`to be a copy of U.S. Patent No. 8,934,535 (the ’535 Patent) and admits that Exhibit B bears on its
`
`2
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`

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`Case 1:18-cv-00927-RBJ Document 28 Filed 06/13/18 USDC Colorado Page 3 of 20
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`face an issue date of January 13, 2015, and the title “Systems and Methods for Video and Audio
`
`Data Storage and Distribution.” Wowza lacks sufficient information to form a belief as to the truth
`
`or falsity of the remaining allegations contained in paragraph 8 of the Complaint and, therefore,
`
`denies them.
`
`9.
`
`Wowza admits that the document attached to the Complaint as Exhibit C purports
`
`to be a copy of U.S. Patent No. 9,769,477 (the ’477 Patent) and admits that Exhibit C bears on its
`
`face an issue date of September 19, 2017, and the title “Video Data Compression Systems.” Wowza
`
`lacks sufficient information to form a belief as to the truth or falsity of the remaining allegations
`
`contained in paragraph 9 of the Complaint and, therefore, denies them.
`
`10. Wowza admits that the document attached to the Complaint as Exhibit D purports
`
`to be a copy of U.S. Patent No. 8,634,462 (the ’462 Patent) and admits that Exhibit D bears on its
`
`face an issue date of January 21, 2014, and the title “Quantization for Hybrid Video Coding.”
`
`Wowza lacks sufficient information to form a belief as to the truth or falsity of the remaining
`
`allegations contained in paragraph 10 of the Complaint and, therefore, denies them.
`
`11. Wowza admits that the document attached to the Complaint as Exhibit E purports
`
`to be a copy of U.S. Patent No. 9,578,298 (the ’298 Patent) and admits that Exhibit E bears on its
`
`face an issue date of February 21, 2017, and the title “Method for Decoding 2D-Compatible
`
`Stereoscopic Video Flows.” Wowza lacks sufficient information to form a belief as to the truth or
`
`falsity of the remaining allegations contained in paragraph 11 of the Complaint and, therefore,
`
`denies them.
`
`COUNT 1: INFRINGEMENT OF U.S. PATENT NO. 7,386,046
`12. Wowza incorporates and restates its responses to the allegations set forth in
`
`paragraphs 1 through 11 of the Complaint.
`
`13. Wowza denies the allegations in paragraph 13 of the Complaint.
`
`3
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`Case 1:18-cv-00927-RBJ Document 28 Filed 06/13/18 USDC Colorado Page 4 of 20
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`14. Wowza denies the allegations in paragraph 14 of the Complaint.
`
`15. Wowza admits that a page on its website available at
`
`https://www.wowza.com/docs/understanding-streaming-protocols-and-output-file-formats states,
`
`“A single Wowza Streaming Engine application can be configured to deliver a stream to Adobe
`
`Flash Player; Microsoft Silverlight; Apple iPhone, iPad, or iPod touch devices; DASH players, and
`
`RTSP/RTP-based players at the same time using the streaming protocols that are described in this
`
`section.” Wowza further admits that a page on its website available at
`
`https://www.wowza.com/docs/understanding-streaming-protocols-and-output-file-formats states,
`
`“Wowza Streaming Engine can stream adaptive bitrate live and VOD H.264, AAC, and MP3
`
`content to iOS-based devices (iPhone/iPad/iPod touch iOS version 3.0 or later), QuickTime player
`
`(version 10 or later), Safari browser (version 4.0 or later), and other devices such as the Roku and
`
`Amino set-top boxes and some brands of smart TVs using the Apple HTTP Live Streaming (Apple
`
`HLS) protocol.” Wowza further admits that a webpage available at
`
`https://developer.Apple.com/library/content/documentation/NetworkingInternet/Conceptual/St
`
`reamingMediaGuide/FrequentlyAskedQuestions/FrequentlyAskedQuestions.html states, “The
`
`protocol specification does not limit the encoder selection. However, the current Apple
`
`implementation should interoperate with encoders that produce MPEG-2 Transport Streams
`
`containing H.264 video and AAC audio (HE-AAC or AAC-LC).” Wowza also admits that a website
`
`available at
`
`https://developer.Apple.com/library/content/documentation/NetworkingInternet/Conceptual/St
`
`reamingMediaGuide/UsingHTTPLiveStreaming/UsingHTTPLiveStreaming.html states, “HTTP
`
`Live Streaming supports switching between streams dynamically if the available bandwidth changes.
`
`The client software uses heuristics to determine appropriate times to switch between the alternates.
`
`Currently, these heuristics are based on recent trends in measured network throughput.” Wowza
`
`4
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`

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`Case 1:18-cv-00927-RBJ Document 28 Filed 06/13/18 USDC Colorado Page 5 of 20
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`further admits that a website available at
`
`https://developer.Apple.com/library/content/documentation/NetworkingInternet/Conceptual/St
`
`reamingMediaGuide/FrequentlyAskedQuestions/FrequentlyAskedQuestions.html states, “The
`
`current implementation of the client observes the effective bandwidth while playing a stream. If a
`
`higher-quality stream is available and the bandwidth appears sufficient to support it, the client
`
`switches to a higher quality. If a lower-quality stream is available and the current bandwidth appears
`
`insufficient to support the current stream, the client switches to a lower quality.” Wowza denies the
`
`remaining allegations in paragraph 25 of the Complaint.
`
`16. Wowza admits that some of its products reference H.264 compression. Wowza
`
`denies the allegations in paragraph 16 of the Complaint.
`
`17. Wowza admits that a page on its website available at
`
`https://www.wowza.com/docs/wowza-transcoder states, “Multiple outbound renditions with
`
`aligned keyframes can be created from the single input stream. As a transrating solution, it can ingest
`
`an H.264 video and AAC/MP3 audio source stream and create a full set of output renditions that
`
`are keyframe-aligned to the original source. The aligned keyframes in the encoded output renditions
`
`enable adaptive bitrate delivery from the Wowza media server over Adobe HDS, Apple HLS,
`
`Microsoft Smooth Streaming, MPEG-DASH, and RTMP streaming protocols to multiple devices.”
`
`Wowza denies the remaining allegations in paragraph 17 of the Complaint.
`
`18. Wowza admits that a webpage available at
`
`https://en.wikipedia.org/wiki/Group_of_pictures states, “The GOP is a collection of successive
`
`pictures within a coded video stream.” Wowza admits that some of its products reference H.264
`
`compression. Wowza denies the remaining allegations in paragraph 18 of the Complaint.
`
`19. Wowza denies the allegations in paragraph 19 of the Complaint.
`
`20. Wowza denies the allegations in paragraph 20 of the Complaint.
`
`5
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`Case 1:18-cv-00927-RBJ Document 28 Filed 06/13/18 USDC Colorado Page 6 of 20
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`21. Wowza admits that a page on its website available at
`
`https://www.wowza.com/docs/wowza-trancoder states, “Multiple outbound renditions with
`
`aligned keyframes can be created from the single input stream. As a transrating solution, it can ingest
`
`an H.264 video and AAC/MP3 audio source stream and create a full set of output renditions that
`
`are keyframe-aligned to the original source. The aligned keyframes in the encoded output renditions
`
`enable adaptive bitrate delivery from the Wowza media server over Adobe HDS, Apple HLS,
`
`Microsoft Smooth Streaming, MPEG-DASH, and RTMP streaming protocols to multiple devices.”
`
`Wowza further admits that a webpage available at
`
`https://developer.Apple.com/library/content/documentation/NetworkingInternet/Conceptual/St
`
`reamingMediaGuide/UsingHTTPLiveStreaming/UsingHTTPLiveStreaming.html states, “HTTP
`
`Live Streaming supports switching between streams dynamically if the available bandwidth changes.
`
`The client software uses heuristics to determine appropriate times to switch between the alternates.
`
`Currently, these heuristics are based on recent trends in measured network throughput.” Wowza
`
`also admits that a webpage available at
`
`https://developer.Apple.com/library/content/documentation/NetworkingInternet/Conceptual/St
`
`reamingMediaGuide/FrequentlyAskedQuestions/FrequentlyAskedQuestions.html states, “The
`
`current implementation of the client observes the effective bandwidth while playing a stream. If a
`
`higher-quality stream is available and the bandwidth appears sufficient to support it, the client
`
`switches to a higher quality. If a lower-quality stream is available and the current bandwidth appears
`
`insufficient to support the current stream, the client switches to a lower quality.” Wowza denies the
`
`remaining allegations in paragraph 21 of the Complaint.
`
`22. Wowza denies the allegations in paragraph 22 of the Complaint.
`
`23. Wowza denies the allegations in paragraph 23 of the Complaint.
`
`24. Wowza denies the allegations in paragraph 24 of the Complaint.
`
`6
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`Case 1:18-cv-00927-RBJ Document 28 Filed 06/13/18 USDC Colorado Page 7 of 20
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`25. Wowza denies the allegations in paragraph 25 of the Complaint.
`
`26. Wowza admits that a page on its website available at
`
`https://www.wowza.com/docs/understanding-streaming-protocols-and-output-file-formats states,
`
`“Wowza Streaming Engine can stream adaptive bitrate live and VOD H.264, AAC, and MP3
`
`content to iOS-based devices (iPhone/iPad/iPod touch iOS version 3.0 or later), QuickTime player
`
`(version 10 or later), Safari browser (version 4.0 or later), and other devices such as the Roku and
`
`Amino set-top boxes and some brands of smart TVs using the Apple HTTP Live Streaming (Apple
`
`HLS) protocol.” Wowza denies the remaining allegations in paragraph 26 of the Complaint.
`
`27. Wowza denies the allegations in paragraph 27 of the Complaint.
`
`28. Wowza denies the allegations in paragraph 28 of the Complaint.
`
`29. Wowza denies the allegations in paragraph 29 of the Complaint.
`
`COUNT 2: INFRINGEMENT OF U.S. PATENT NO. 8,934,535
`30. Wowza incorporates and restates its responses to the allegations set forth in
`
`paragraphs 1 through 29 of the Complaint.
`
`31. Wowza denies the allegations in paragraph 31 of the Complaint.
`
`32. Wowza denies the allegations in paragraph 32 of the Complaint.
`
`33. Wowza admits that a page on its website available at
`
`https://www.wowza.com/docs/understanding-streaming-protocols-and-output-file-formats states,
`
`“A single Wowza Streaming Engine application can be configured to deliver a stream to Adobe
`
`Flash Player; Microsoft Silverlight; Apple iPhone, iPad, or iPod touch devices; DASH players, and
`
`RTSP/RTP-based players at the same time using the streaming protocols that are described in this
`
`section.” Wowza further admits that a page on its website available at
`
`https://www.wowza.com/docs/understanding-streaming-protocols-and-output-file-formats states,
`
`“Wowza Streaming Engine can stream adaptive bitrate live and VOD H.264, AAC, and MP3
`
`7
`
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`

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`content to iOS-based devices (iPhone/iPad/iPod touch iOS version 3.0 or later), QuickTime player
`
`(version 10 or later), Safari browser (version 4.0 or later), and other devices such as the Roku and
`
`Amino set-top boxes and some brands of smart TVs using the Apple HTTP Live Streaming (Apple
`
`HLS) protocol.” Wowza also admits that a webpage available at
`
`https://developer.Apple.com/library/content/documentation/NetworkingInternet/Conceptual/St
`
`reamingMediaGuide/FrequentlyAskedQuestions/FrequentlyAskedQuestions.html states, “The
`
`protocol specification does not limit the encoder selection. However, the current Apple
`
`implementation should interoperate with encoders that produce MPEG-2 Transport Streams
`
`containing H.264 video and AAC audio (HE-AAC or AAC-LC).” Wowza also admits that a
`
`webpage available at
`
`https://developer.Apple.com/library/content/documentation/NetworkingInternet/Conceptual/St
`
`reamingMediaGuide/UsingHTTPLiveStreaming/UsingHTTPLiveStreaming.html states, “HTTP
`
`Live Streaming supports switching between streams dynamically if the available bandwidth changes.
`
`The client software uses heuristics to determine appropriate times to switch between the alternates.
`
`Currently, these heuristics are based on recent trends in measured network throughput.” Wowza
`
`also admits that a webpage available at
`
`https://developer.Apple.com/library/content/documentation/NetworkingInternet/Conceptual/St
`
`reamingMediaGuide/FrequentlyAskedQuestions/FrequentlyAskedQuestions.html states, “The
`
`current implementation of the client observes the effective bandwidth while playing a stream. If a
`
`higher-quality stream is available and the bandwidth appears sufficient to support it, the client
`
`switches to a higher quality. If a lower-quality stream is available and the current bandwidth appears
`
`insufficient to support the current stream, the client switches to a lower quality.” Wowza admits that
`
`some of its products reference H.264 compression. Wowza denies the remaining allegations in
`
`paragraph 33 of the Complaint.
`
`8
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`34. Wowza denies the allegations in paragraph 34 of the Complaint.
`
`35. Wowza admits that a webpage available at
`
`https://en.wikipedia.org/wiki/Group_of_pictures states, “The GOP is a collection of successive
`
`pictures within a coded video stream.” Wowza denies the remaining allegations in paragraph 35 of
`
`the Complaint.
`
`36. Wowza denies the allegations in paragraph 36 of the Complaint.
`
`37. Wowza denies the allegations in paragraph 37 of the Complaint.
`
`38. Wowza denies the allegations in paragraph 38 of the Complaint.
`
`39. Wowza admits that a page available on its website available at
`
`https://www.wowza.com/docs/wowza-transcoder states, “Multiple outbound renditions with
`
`aligned keyframes can be created from the single input stream. As a transrating solution, it can ingest
`
`an H.264 video and AAC/MP3 audio source stream and create a full set of output renditions that
`
`are keyframe-aligned to the original source. The aligned keyframes in the encoded output renditions
`
`enable adaptive bitrate delivery from the Wowza media server over Adobe HDS, Apple HLS,
`
`Microsoft Smooth Streaming, MPEG-DASH, and RTMP streaming protocols to multiple devices.”
`
`Wowza denies the remaining allegations in paragraph 39 of the Complaint.
`
`40. Wowza denies the allegations in paragraph 40 of the Complaint.
`
`41. Wowza denies the allegations in paragraph 41 of the Complaint.
`
`42. Wowza denies the allegations in paragraph 42 of the Complaint.
`
`43. Wowza denies the allegations in paragraph 43 of the Complaint.
`
`44. Wowza denies the allegations in paragraph 44 of the Complaint.
`
`45. Wowza admits that a page on its website available at
`
`https://www.wowza.com/docs/understanding-streaming-protocols-and-output-file-formats states,
`
`“Wowza Streaming Engine can stream adaptive bitrate live and VOD H.264, AAC, and MP3
`
`9
`
`
`

`

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`content to iOS-based devices (iPhone/iPad/iPod touch iOS version 3.0 or later), QuickTime player
`
`(version 10 or later), Safari browser (version 4.0 or later), and other devices such as the Roku and
`
`Amino set-top boxes and some brands of smart TVs using the Apple HTTP Live Streaming (Apple
`
`HLS) protocol.” Wowza denies the remaining allegations in paragraph 45 of the Complaint.
`
`46. Wowza denies the allegations in paragraph 46 of the Complaint.
`
`47. Wowza denies the allegations in paragraph 47 of the Complaint.
`
`48. Wowza denies the allegations in paragraph 48 of the Complaint.
`
`COUNT 3: INFRINGEMENT OF U.S. PATENT NO. 8,769,477
`49. Wowza incorporates and restates its responses to the allegations set forth in
`
`paragraphs 1 through 48 of the Complaint.
`
`50. Wowza denies the allegations in paragraph 50 of the Complaint.
`
`51. Wowza denies the allegations in paragraph 51 of the Complaint.
`
`52. Wowza admits that a page on its website available at
`
`https://www.wowza.com/docs/understanding-streaming-protocols-and-output-file-formats states,
`
`“A single Wowza Streaming Engine application can be configured to deliver a stream to Adobe
`
`Flash Player; Microsoft Silverlight; Apple iPhone, iPad, or iPod touch devices; DASH players, and
`
`RTSP/RTP-based players at the same time using the streaming protocols that are described in this
`
`section.” Wowza also admits that a page on its website available at
`
`https://www.wowza.com/docs/understanding-streaming-protocols-and-output-file-formats states,
`
`“Wowza Streaming Engine can stream adaptive bitrate live and VOD H.264, AAC, and MP3
`
`content to iOS-based devices (iPhone/iPad/iPod touch iOS version 3.0 or later), QuickTime player
`
`(version 10 or later), Safari browser (version 4.0 or later), and other devices such as the Roku and
`
`Amino set-top boxes and some brands of smart TVs using the Apple HTTP Live Streaming (Apple
`
`HLS) protocol.” Wowza admits that a webpage available at
`
`10
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`Case 1:18-cv-00927-RBJ Document 28 Filed 06/13/18 USDC Colorado Page 11 of 20
`
`https://developer.Apple.com/library/content/documentation/NetworkingInternet/Conceptual/St
`
`reamingMediaGuide/FrequentlyAskedQuestions/FrequentlyAskedQuestions.html states, “The
`
`protocol specification does not limit the encoder selection. However, the current Apple
`
`implementation should interoperate with encoders that produce MPEG-2 Transport Streams
`
`containing H.264 video and AAC audio (HE-AAC or AAC-LC).” Wowza also admits that a
`
`webpage available at
`
`https://developer.Apple.com/library/content/documentation/NetworkingInternet/Conceptual/St
`
`reamingMediaGuide/UsingHTTPLiveStreaming/UsingHTTPLiveStreaming.html states, “HTTP
`
`Live Streaming supports switching between streams dynamically if the available bandwidth changes.
`
`The client software uses heuristics to determine appropriate times to switch between the alternates.
`
`Currently, these heuristics are based on recent trends in measured network throughput.” Wowza
`
`admits that a webpage available at
`
`https://developer.Apple.com/library/content/documentation/NetworkingInternet/Conceptual/St
`
`reamingMediaGuide/FrequentlyAskedQuestions/FrequentlyAskedQuestions.html states, “The
`
`current implementation of the client observes the effective bandwidth while playing a stream. If a
`
`higher-quality stream is available and the bandwidth appears sufficient to support it, the client
`
`switches to a higher quality. If a lower-quality stream is available and the current bandwidth appears
`
`insufficient to support the current stream, the client switches to a lower quality.” Wowza admits that
`
`some of its products reference H.264 compression. Wowza denies the remaining allegations in
`
`paragraph 52 of the Complaint.
`
`53. Wowza denies the allegations in paragraph 53 of the Complaint.
`
`54. Wowza admits that a webpage available at
`
`https://en.wikipedia.org/wiki/Group_of_pictures states, “The GOP is a collection of successive
`
`11
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`pictures within a coded video stream.” Wowza denies the remaining allegations in paragraph 54 of
`
`the Complaint.
`
`55. Wowza denies the allegations in paragraph 55 of the Complaint.
`
`56. Wowza admits that a page on its website available at
`
`https://www.wowza.com/docs/wowza-transcoder states, “Multiple outbound renditions with
`
`aligned keyframes can be created from the single input stream. As a transrating solution, it can ingest
`
`an H.264 video and AAC/MP3 audio source stream and create a full set of output renditions that
`
`are keyframe-aligned to the original source. The aligned keyframes in the encoded output renditions
`
`enable adaptive bitrate delivery from the Wowza media server over Adobe HDS, Apple HLS,
`
`Microsoft Smooth Streaming, MPEG-DASH, and RTMP streaming protocols to multiple devices.”
`
`Wowza denies the remaining allegations in paragraph 56 of the Complaint.
`
`57. Wowza denies the allegations in paragraph 57 of the Complaint.
`
`58. Wowza denies the allegations in paragraph 58 of the Complaint.
`
`59. Wowza denies the allegations in paragraph 59 of the Complaint.
`
`60. Wowza denies the allegations in paragraph 60 of the Complaint.
`
`61. Wowza denies the allegations in paragraph 61 of the Complaint.
`
`62. Wowza denies the allegations in paragraph 62 of the Complaint.
`
`63. Wowza denies the allegations in paragraph 63 of the Complaint.
`
`64. Wowza admits that a page on its website available at
`
`https://www.wowza.com/docs/understanding-streaming-protocols-and-output-file-formats states,
`
`“Wowza Streaming Engine can stream adaptive bitrate live and VOD H.264, AAC, and MP3
`
`content to iOS-based devices (iPhone/iPad/iPod touch iOS version 3.0 or later), QuickTime player
`
`(version 10 or later), Safari browser (version 4.0 or later), and other devices such as the Roku and
`
`12
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`Case 1:18-cv-00927-RBJ Document 28 Filed 06/13/18 USDC Colorado Page 13 of 20
`
`Amino set-top boxes and some brands of smart TVs using the Apple HTTP Live Streaming (Apple
`
`HLS) protocol.” Wowza denies the remaining allegations in paragraph 64 of the Complaint.
`
`65. Wowza denies the allegations in paragraph 65 of the Complaint.
`
`66. Wowza denies the allegations in paragraph 66 of the Complaint.
`
`67. Wowza denies the allegations in paragraph 67 of the Complaint.
`
`COUNT 4: INFRINGEMENT OF U.S. PATENT NO. 8,634,462
`68. Wowza incorporates and restates its responses to the allegations set forth in
`
`paragraphs 1 through 67 of the Complaint.
`
`69. Wowza denies the allegations in paragraph 69 of the Complaint.
`
`70. Wowza denies the allegations in paragraph 70 of the Complaint.
`
`71. Wowza admits that a page on its website available at
`
`https://www.wowza.com/docs/how-to-stream-using-hevc-h-265-transcoding states, “This section
`
`explains how to configure Wowza Streaming Engine software to transcode a live video stream to
`
`H.265 for MPEG-DASH playback in DivX Web Player and MPEG-DASH/Apple HLS playback in
`
`VLC media player.” Wowza denies the remaining allegations in paragraph 71 of the Complaint.
`
`72. Wowza denies the allegations in paragraph 72 of the Complaint.
`
`73. Wowza admits that the ITU-T H.265 Series H: Audiovisual and Multimedia Systems,
`
`Infrastructure of Audiovisual Services  Coding of Moving Video, High Efficiency Video Coding
`
`document states, “bitstream: A sequence of bits, in the form of a NAL unit stream or a byte stream,
`
`that forms the representation of coded pictures and associated data forming one or more coded video
`
`sequences (CVSs).” Wowza also admits that an article entitled Overview of the High Efficiency
`
`Video Coding (HEVC) Standard written by Gary Sullivan states, “The video coding layer of HEVC
`
`employs the same hybrid approach (inter-/intrapicture prediction and 2-D transform coding) used
`
`in all video compression standards since H.261.” Wowza denies that the quoted portions of the
`
`13
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`Case 1:18-cv-00927-RBJ Document 28 Filed 06/13/18 USDC Colorado Page 14 of 20
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`documents are full, complete, and accurate descriptions of the Accused HEVC Products. Wowza
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`denies the remaining allegations in paragraph 73 of the Complaint.
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`74. Wowza denies the allegations in paragraph 74 of the Complaint.
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`75. Wowza denies the allegations in paragraph 75 of the Complaint.
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`76. Wowza admits that an article entitled Overview of the High Efficiency Video Coding
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`(HEVC) Standard written by Gary Sullivan states, “Prediction units and prediction blocks (PBs):
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`The decision whether to code a picture area using interpicture or intrapicture prediction is made at
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`the CU level. A PU partitioning structure has its root at the CU level. Depending on the basic
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`prediction-type decision, the luma and chroma CBs can then be further split in size and predicted
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`from luma and chroma prediction blocks (PBs). HEVC supports variable PB sizes from 64x64
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`down to 4x4 samples.” Wowza denies that the quoted portion of the document is a full, complete,
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`and accurate description of the Accused HEVC Products. Wowza denies the remaining allegations
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`in paragraph 76 of the Complaint.
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`77. Wowza admits that the ITU-T H.265 Series H: Audiovisual and Multimedia Systems,
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`Infrastructure of Audiovisual Services  Coding of Moving Video, High Efficiency Video Coding
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`document states, “coded_sub_block_flag[ xS ][ yS ] specifies the following for the sub-block at
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`location ( xS, yS ) within the current transform block, where a sub-block is a (4x4) array of 16
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`transform coefficient levels: If coded_sub_block_flag[ xS ][ yS ] is equal to 0, the 16 transform
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`coefficient levels of the sub-block at location ( xS, yS ) are inferred to be equal to 0.” Wowza denies
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`that the quoted portion of the document is a full, complete, and accurate description of the Accused
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`HEVC Products. Wowza denies the remaining allegations in paragraph 77 of the Complaint.
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`78. Wowza admits that the ITU-T H.265 Series H: Audiovisual and Multimedia Systems,
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`Infrastructure of Audiovisual Services  Coding of Moving Video, High Efficiency Video Coding
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`document states, “Otherwise (coded_sub_block_flag[ xS ][ yS ] is equal to 1), the following applies:
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`Case 1:18-cv-00927-RBJ Document 28 Filed 06/13/18 USDC Colorado Page 15 of 20
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`If ( xS, yS ) is equal to ( 0, 0 ) and ( LastSignificantCoeffX, LastSignificantCoeffY ) is not equal to
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`( 0, 0 ), at least one of the 16 sig_coeff_flag syntax elements is present for the sub-block at location
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`( xS, yS ). Otherwise, at least one of the 16 transform coefficient levels of the sub-block at location
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`( xS, yS ) has a non zero value. When coded_sub_block_flag[ xS ][ yS ] is not present, it is inferred as
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`follows: If one or more of the following conditions are true, coded_sub_block_flag[ xS ][ yS ] is
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`inferred to be equal to 1: ( xS, yS ) is equal to ( 0, 0 ) ( xS, yS ) is equal to
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`( LastSignificantCoeffX >> 2, LastSignificantCoeffY >> 2 ) Otherwise,
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`coded_sub_block_flag[ xS ][ yS ] is inferred to be equal to 0.” Wowza denies that the quoted portion
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`of the document is a full, complete, and accurate description of the Accused HEVC Products.
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`Wowza denies the remaining allegations in paragraph 78 of the Complaint.
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`79. Wowza denies the allegations in paragraph 79 of the Complaint.
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`80. Wowza denies the allegations in paragraph 80 of the Complaint.
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`81. Wowza denies the allegations in paragraph 81 of the Complaint.
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`82. Wowza denies the allegations in paragraph 82 of the Complaint.
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`83. Wowza denies the allegations in paragraph 83 of the Complaint.
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`84. Wowza denies the allegations in paragraph 84 of the Complaint.
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`85. Wowza denies the allegations in paragraph 85 of the Complaint.
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`86. Wowza denies the allegations in paragraph 86 of the Complaint.
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`87. Wowza denies the allegations in paragraph 87 of the Complaint.
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`88. Wowza denies the allegations in paragraph 88 of the Complaint.
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`89. Wowza denies the allegations in paragraph 89 of the Complaint.
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`90. Wowza denies the allegations in paragraph 90 of the Complaint.
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`91. Wowza denies the allegations in paragraph 91 of the Complaint.
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`Case 1:18-cv-00927-RBJ Document 28 Filed 06/13/18 USDC Colorado Page 16 of 20
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`COUNT 5: INFRINGEMENT OF U.S. PATENT NO. 9,578,298
`92. Wowza incorporates and restates its responses to the allegations set forth in
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`paragraphs 1 through 91 of the Complaint.
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`93. Wowza denies the allegations in paragraph 93 of the Complaint.
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`94. Wowza denies the allegations in paragraph 94 of the Complaint.
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`95. Wowza admits that a page on its website available at
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`https://www.wowza.com/products/capabilities/live-transcoding lists transcoder specifications.
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`Wowza denies the remaining allegations in paragraph 95 of the Complaint.
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`96. Wowza denies the allegations in paragraph 96 of the Complaint.
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`97. Wowza admits that the ITU-T H.265 Series H: Audiovisual and Multimedia Systems,
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`Infrastructure of Audiovisual Services  Coding of Moving Video, High Efficiency Video Coding
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`document states, “3.39 decoded picture: A decoded picture is derived by decoding a coded picture.”
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`Wowza admits that the ITU-T H.265 Series H: Audiovisual and Multimedia Systems, Infrastructure
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`of Audiovisual Services  Coding of Moving Video, High Efficiency Video Coding document also
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`states, “3.37 display process: A process not specified in this Specification having, as its input, the
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`cropped decoded pictures that are the output of the decoding process.” Wowza denies that the quoted
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`portions of the document are a full, complete, and accurate description of the Accused HEVC
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`Products. Wowza denies the remaining allegations in paragraph 97 of the Complaint.
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`98. Wowza admits that the ITU-T H.265 Series H: Audiovisual and Multimedia Systems,
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`Infrastructure of Audiovisual Services  Coding of Moving Video, High Efficiency Video Coding
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`document states, “NOTE 9 – The default display window parameters in the VUI parameters of the
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`SPS can be used by an encoder to indicate to a decoder that does not interpret the frame packing
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`arrangement SEI message that the default display window is an area within only one of the two
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`constituent frames.” Wowza denies that the quoted portion of the document is a full, complete, and
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`Case 1:18-cv-00927-RBJ Document 28 Filed 06/13/18 USDC Colorado Page 17 of 20
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