Case 1:14-cv-01430-LPS Document 313 Filed 07/08/20 Page 1 of 29 PageID #: 21270
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`ELM 3DS INNOVATIONS, LLC, a
`Delaware limited liability company,
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`Plaintiff,
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`v.
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`SAMSUNG ELECTRONICS CO., LTD., a
`Korean business entity,
`SAMSUNG SEMICONDUCTOR, INC., a
`California corporation,
`SAMSUNG ELECTRONICS AMERICA,
`INC., a New York corporation, and
`SAMSUNG AUSTIN SEMICONDUCTOR,
`LLC, a Delaware limited liability company,
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`Defendants.
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`C.A. No. 14-1430-LPS
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`JURY TRIAL DEMANDED
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`SAMSUNG ELECTRONICS CO., LTD., SAMSUNG SEMICONDUCTOR, INC.,
`SAMSUNG ELECTRONICS AMERICA, INC., AND SAMSUNG AUSTIN
`SEMICONDUCTOR, LLC’S ANSWER AND DEFENSES TO ELM 3DS INNOVATIONS,
`LLC’S SECOND AMENDED COMPLAINT FOR PATENT INFRINGEMENT,
`AND DEMAND FOR JURY TRIAL
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`Samsung Electronics Co., Ltd. (“SEC”); Samsung Semiconductor, Inc. (“SSI”); Samsung
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`Electronics America, Inc. (“SEA”); and Samsung Austin Semiconductor, LLC (“SAS”)
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`(collectively, the “Samsung Defendants”) respond to the allegations in the Second Amended
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`Complaint for Patent Infringement (“SAC”) of Plaintiff Elm 3DS Innovations, LLC (“Elm 3DS”
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`or “Plaintiff”) as follows:
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`

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`Case 1:14-cv-01430-LPS Document 313 Filed 07/08/20 Page 2 of 29 PageID #: 21271
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`GENERAL DENIAL
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`Unless specifically admitted below, the Samsung Defendants deny Plaintiff’s allegations
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`of infringement. For convenience and clarity, the Samsung Defendants’ Answer references
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`headings as set forth in Plaintiff’s SAC. In so doing, the Samsung Defendants do not admit any
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`of the allegations contained in Plaintiff’s headings.
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`INTRODUCTION
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`1.
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`The Samsung Defendants admit that this action purports to arise under the Patent
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`Laws of the United States, 35 U.S.C. Title 35 § 1 et seq. alleging infringement of U.S. Patent Nos.
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`7,193,239; 7,474,004; 7,504,732; 8,410,617; 8,629,542; 8,653,672; 8,796,862; 8,841,778;
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`8,907,499; 8,928,119; 8,933,570; and 8,791,581 (collectively, the “Asserted Patents”). The
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`Samsung Defendants further admit that uncertified copies of the Asserted Patents are attached to
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`the SAC as Exhibits 1 through 12. The Samsung Defendants lack knowledge or information
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`sufficient to form a belief as to whether Elm 3DS is the current owner of all rights, title, and interest
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`in and to the Asserted Patents, and therefore denies such allegations. The Samsung Defendants
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`deny infringing the Asserted Patents. Except as expressly admitted, the Samsung Defendants deny
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`the remaining allegations of Paragraph 1 of the SAC.
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`2.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 2, and therefore deny them.
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`3.
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`4.
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`The Samsung Defendants deny the allegations of Paragraph 3 of the SAC.
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`Paragraph 4 of the SAC contains no allegation to which a response is required. To
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`the extent a response is required; the Samsung Defendants deny infringing the Asserted Patents.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief as to the truth
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`of any remaining allegations in Paragraph 4, and therefore deny them.
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`2
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`Case 1:14-cv-01430-LPS Document 313 Filed 07/08/20 Page 3 of 29 PageID #: 21272
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`THE PARTIES
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`5.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 5, and therefore deny them.
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`6.
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`SEC admits that it is a foreign company organized and existing under the laws of
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`the Republic of Korea, with its principal place of business at 129 Samsung-ro, Yeongtong-gu,
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`Suwon-si, Gyeonggi-do, 443742, South Korea. The Samsung Defendants admit that SEC is South
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`Korea’s largest company and one of Asia’s largest electronics companies. The Samsung
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`Defendants admit that SEC designs, develops, manufactures and provides to the U.S. and world
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`markets a wide range of innovative products, including semiconductors, consumer electronics,
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`computer components, and mobile and entertainment products. Except as expressly admitted, the
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`Samsung Defendants deny the remaining allegations of Paragraph 6.
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`7.
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`SEA admits it is a corporation organized and existing under the laws of New York,
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`with its principal place of business at 85 Challenger Road, Ridgefield Park, New Jersey 07660.
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`SEA admits it is a wholly-owned subsidiary of SEC. The Samsung Defendants admit that SEA
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`offers a full range of innovative, award-winning electronics and IT products including, but not
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`limited to, handheld wireless phones, wireless communications infrastructure systems, televisions,
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`Blu-ray Disc players, digital cameras and camcorders, certain memory storage devices, portable
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`audio devices, printers and monitors. Except as expressly admitted, the Samsung Defendants deny
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`the remaining allegations of Paragraph 7.
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`8.
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`SSI admits it is a corporation organized and existing under the laws of California,
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`with its principal place of business at 3655 North First Street, San Jose, California 95134. SSI
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`admits it is a wholly-owned subsidiary of SEA. The Samsung Defendants admit that SSI offers
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`3
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`Case 1:14-cv-01430-LPS Document 313 Filed 07/08/20 Page 4 of 29 PageID #: 21273
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`innovative, award-winning semiconductor products. Except as expressly admitted, the Samsung
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`Defendants deny the remaining allegations of Paragraph 8.
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`9.
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`SAS admits it is a limited liability company organized and existing under the laws
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`of Delaware, with its principal place of business at 12100 Samsung Boulevard, Austin, Texas
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`78754. SAS admits it is a wholly-owned subsidiary of SSI. Except as expressly admitted, the
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`Samsung Defendants deny the remaining allegations of Paragraph 9.
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`JURISDICTION
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`10.
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`The Samsung Defendants admit that the SAC purports to set forth an action for
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`patent infringement and that this Court has subject matter jurisdiction pursuant to 28 U.S.C.
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`§§ 1331 and 1338.
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`11.
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`The Samsung Defendants will not challenge personal jurisdiction in the District of
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`Delaware for purposes of this case only. SAS admits that it is organized under the laws of
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`Delaware. Except as expressly admitted, the Samsung Defendants deny the remaining allegations
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`of Paragraph 11.
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`VENUE
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`12.
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`The Samsung Defendants will not contest the propriety of venue for purposes of
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`this action only. Except as expressly admitted, the Samsung Defendants deny the remaining
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`allegations of Paragraph 12.
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`FACTUAL BACKGROUND
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`(The Asserted Patents)
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`13.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 13, and therefore deny them.
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`4
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`Case 1:14-cv-01430-LPS Document 313 Filed 07/08/20 Page 5 of 29 PageID #: 21274
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`(a)
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`The Samsung Defendants admit that U.S. Patent No. 7,193,239 (“the ’239
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`Patent”) is entitled “Three Dimensional Structure Integrated Circuit”; indicates that the inventor is
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`Glenn J. Leedy; and indicates that it was issued on March 20, 2007. The Samsung Defendants
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`lack knowledge or information sufficient to form a belief as to whether Elm 3DS owns all rights,
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`titles, and interest in and to the ’239 Patent, and whether the ’239 Patent was duly and legally
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`issued. Except as expressly admitted, the Samsung Defendants lack knowledge or information
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`sufficient to form a belief as to the truth of the remaining allegations of Paragraph 13(a), and
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`therefore deny them.
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`(b)
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`The Samsung Defendants admit that U.S. Patent No. 7,474,004 (“the Leedy
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`’004”) is entitled “Three Dimensional Structure Memory”; indicates that the inventor is Glenn J.
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`Leedy; and indicates that it was issued on January 6, 2009. The Samsung Defendants lack
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`knowledge or information sufficient to form a belief as to whether Elm 3DS owns all rights, titles,
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`and interest in and to the ’004 Patent, and whether the ’004 Patent was duly and legally issued.
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`Except as expressly admitted, the Samsung Defendants lack knowledge or information sufficient
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`to form a belief as to the truth of the remaining allegations of Paragraph 13(b), and therefore deny
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`them.
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`(c)
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`The Samsung Defendants admit that U.S. Patent No. 7,504,732 (“the ’732
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`Patent”) is entitled “Three Dimensional Structure Memory”; indicates that the inventor is Glenn J.
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`Leedy; and indicates that it was issued on March 17, 2009. The Samsung Defendants lack
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`knowledge or information sufficient to form a belief as to whether Elm 3DS owns all rights, titles,
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`and interest in and to the ’732 Patent, and whether the ’732 Patent was duly and legally issued.
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`Except as expressly admitted, the Samsung Defendants lack knowledge or information sufficient
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`Case 1:14-cv-01430-LPS Document 313 Filed 07/08/20 Page 6 of 29 PageID #: 21275
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`to form a belief as to the truth of the remaining allegations of Paragraph 13(c), and therefore deny
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`them.
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`(d)
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`The Samsung Defendants admit that U.S. Patent No. 8,410,617 (“the ’617
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`Patent”) is entitled “Three Dimensional Structure Memory”; indicates that the inventor is Glenn J.
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`Leedy; and indicates that it was issued on April 2, 2013. The Samsung Defendants lack knowledge
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`or information sufficient to form a belief as to whether Elm 3DS owns all rights, titles, and interest
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`in and to the ’617 Patent, and whether the ’617 Patent was duly and legally issued. Except as
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`expressly admitted, the Samsung Defendants lack knowledge or information sufficient to form a
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`belief as to the truth of the remaining allegations of Paragraph 13(e), and therefore deny them.
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`(e)
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`The Samsung Defendants admit that U.S. Patent No. 8,629,542 (“the ’542
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`Patent”) is entitled “Three Dimensional Structure Memory”; indicates that the inventor is Glenn J.
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`Leedy; and indicates that it was issued on January 14, 2014. The Samsung Defendants lack
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`knowledge or information sufficient to form a belief as to whether Elm 3DS owns all rights, titles,
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`and interest in and to the ’542 Patent, and whether the ’542 Patent was duly and legally issued.
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`Except as expressly admitted, the Samsung Defendants lack knowledge or information sufficient
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`to form a belief as to the truth of the remaining allegations of Paragraph 13(f), and therefore deny
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`them.
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`(f)
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`The Samsung Defendants admit that U.S. Patent No. 8,653,672 (“the ’672
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`Patent”) is entitled “Three Dimensional Structure Memory”; indicates that the inventor is Glenn J.
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`Leedy; and indicates that it was issued on February 18, 2014. The Samsung Defendants lack
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`knowledge or information sufficient to form a belief as to whether Elm 3DS owns all rights, titles,
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`and interest in and to the ’672 Patent, and whether the ’672 Patent was duly and legally issued.
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`Except as expressly admitted, the Samsung Defendants lack knowledge or information sufficient
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`6
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`Case 1:14-cv-01430-LPS Document 313 Filed 07/08/20 Page 7 of 29 PageID #: 21276
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`to form a belief as to the truth of the remaining allegations of Paragraph 13(g), and therefore deny
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`them.
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`(g)
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`The Samsung Defendants admit that U.S. Patent No. 8,796,862 (“the ’862
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`Patent”) is entitled “Three Dimensional Structure Memory”; indicates that the inventor is Glenn J.
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`Leedy; and indicates that it was issued on August 5, 2014. The Samsung Defendants lack
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`knowledge or information sufficient to form a belief as to whether Elm 3DS owns all rights, titles,
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`and interest in and to the ’862 Patent, and whether the ’862 Patent was duly and legally issued.
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`Except as expressly admitted, the Samsung Defendants lack knowledge or information sufficient
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`to form a belief as to the truth of the remaining allegations of Paragraph 13(h), and therefore deny
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`them.
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`(h)
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`The Samsung Defendants admit that U.S. Patent No. 8,841,778 (“the ’778
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`Patent”) is entitled “Three Dimensional Memory Structure”; indicates that the inventor is Glenn J.
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`Leedy; and indicates that it was issued on September 23, 2014. The Samsung Defendants lack
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`knowledge or information sufficient to form a belief as to whether Elm 3DS owns all rights, titles,
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`and interest in and to the ’778 Patent, and whether the ’778 Patent was duly and legally issued.
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`Except as expressly admitted, the Samsung Defendants lack knowledge or information sufficient
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`to form a belief as to the truth of the remaining allegations of Paragraph 13(i), and therefore deny
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`them.
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`(i)
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`The Samsung Defendants admit that U.S. Patent No. 8,907,499 (“the ’499
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`Patent”) is entitled “Three Dimensional Structure Memory”; indicates that the inventor is Glenn J.
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`Leedy; and indicates that it was issued on December 9, 2014. The Samsung Defendants lack
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`knowledge or information sufficient to form a belief as to whether Elm 3DS owns all rights, titles,
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`and interest in and to the ’499 Patent, and whether the ’499 Patent was duly and legally issued.
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`7
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`Case 1:14-cv-01430-LPS Document 313 Filed 07/08/20 Page 8 of 29 PageID #: 21277
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`Except as expressly admitted, the Samsung Defendants lack knowledge or information sufficient
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`to form a belief as to the truth of the remaining allegations of Paragraph 13(j), and therefore deny
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`them.
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`(j)
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`The Samsung Defendants admit that U.S. Patent No. 8,928,119 (“the ’119
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`Patent”) is entitled “Three Dimensional Structure Memory”; indicates that the inventor is Glenn J.
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`Leedy; and indicates that it was issued on January 6, 2015. The Samsung Defendants lack
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`knowledge or information sufficient to form a belief as to whether Elm 3DS owns all rights, titles,
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`and interest in and to the ’119 Patent, and whether the ’119 Patent was duly and legally issued.
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`Except as expressly admitted, the Samsung Defendants lack knowledge or information sufficient
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`to form a belief as to the truth of the remaining allegations of Paragraph 13(k), and therefore deny
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`them.
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`(k)
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`The Samsung Defendants admit that U.S. Patent No. 8,933,570 (“the ’570
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`Patent”) is entitled “Three Dimensional Structure Memory”; indicates that the inventor is Glenn J.
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`Leedy; and indicates that it was issued on January 13, 2015. The Samsung Defendants lack
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`knowledge or information sufficient to form a belief as to whether Elm 3DS owns all rights, titles,
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`and interest in and to the ’570 Patent, and whether the ’570 Patent was duly and legally issued.
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`Except as expressly admitted, the Samsung Defendants lack knowledge or information sufficient
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`to form a belief as to the truth of the remaining allegations of Paragraph 13(l), and therefore deny
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`them.
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`(l)
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`The Samsung Defendants admit that U.S. Patent No. 8,791,581 (“the ’581
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`Patent”) is entitled “Three Dimensional Structure Memory”; indicates that the inventor is Glenn J.
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`Leedy; and indicates that it was issued on July 29, 2014. The Samsung Defendants lack knowledge
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`or information sufficient to form a belief as to whether Elm 3DS owns all rights, titles, and interest
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`8
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`Case 1:14-cv-01430-LPS Document 313 Filed 07/08/20 Page 9 of 29 PageID #: 21278
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`in and to the ’581 Patent, and whether the ’581 Patent was duly and legally issued. Except as
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`expressly admitted, the Samsung Defendants lack knowledge or information sufficient to form a
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`belief as to the truth of the remaining allegations of Paragraph 13(m), and therefore deny them.
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`The Samsung Defendants deny that each of the ’239 Patent, the ’004 Patent, the ’732
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`Patent, the ’617 Patent, the ’542 Patent, the ’672 Patent, the ’862 Patent, the ’778 Patent, the ’499
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`Patent, the ’119 Patent, the ’570 Patent, and the ’581 Patent is valid and enforceable.
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`14.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 14, and therefore deny them.
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`(The Purported Inventor)
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`15.
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`The Samsung Defendants admit that the Asserted Patents identify Glenn J. Leedy
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`as the named inventor. Except as expressly admitted, the Samsung Defendants lack knowledge or
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`information sufficient to form a belief as to the truth of the remaining allegations of Paragraph 15,
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`and therefore deny them.
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`16.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 16, and therefore deny them.
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`17.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 17, and therefore deny them.
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`18.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 18, and therefore deny them.
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`19.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 19, and therefore deny them.
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`20.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 20, and therefore deny them.
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`9
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`Case 1:14-cv-01430-LPS Document 313 Filed 07/08/20 Page 10 of 29 PageID #: 21279
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`21.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 21 and therefore deny them.
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`22.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 22, and therefore deny them.
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`23.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 23, and therefore deny them.
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`24.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 24, and therefore deny them.
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`25.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 25, and therefore deny them.
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`26.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 26, and therefore deny them.
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`27.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 27, and therefore deny them.
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`28.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 28, and therefore deny them.
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`29.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 29, and therefore deny them.
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`30.
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`The Samsung Defendants deny use of the Asserted Patents and Mr. Leedy’s 3DS
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`technology. The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the remaining allegations of Paragraph 30, and therefore deny them.
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`31.
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`The Samsung Defendants aver that the document attached as Exhibit 13 speaks for
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`itself and deny the allegations of Paragraph 31 to the extent they do not accurately describe the
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`10
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`Case 1:14-cv-01430-LPS Document 313 Filed 07/08/20 Page 11 of 29 PageID #: 21280
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`document. The Samsung Defendants lack knowledge or information sufficient to form a belief as
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`to the truth of the remaining allegations of Paragraph 31, and therefore deny them.
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`32.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 32, and therefore deny them.
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`(The Purported Meeting With Defendants)
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`33.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 33, and therefore deny them.
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`(The Purported Direct Infringement)
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`34.
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`The Samsung Defendants deny the implication that the legal test for infringement
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`requires an analysis of “Mr. Leedy’s 3DS technology” and deny the remaining allegations of
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`Paragraph 34.
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`35.
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`The Samsung Defendants aver that the document attached as Exhibit 14 speaks for
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`itself and deny the allegations of Paragraph 35 to the extent they do not accurately describe the
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`document. The Samsung Defendants lack knowledge or information sufficient to form a belief as
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`to the truth of the remaining allegations of Paragraph 35, and therefore deny them.
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`36.
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`The Samsung Defendants aver that the document attached as Exhibit 14 speaks for
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`itself and deny the allegations of Paragraph 36 to the extent they do not accurately describe the
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`document. The Samsung Defendants lack knowledge or information sufficient to form a belief as
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`to the truth of the remaining allegations of Paragraph 36, and therefore deny them.
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`37.
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`The Samsung Defendants aver that the document attached as Exhibit 14 speaks for
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`itself and deny the allegations of Paragraph 37 to the extent they do not accurately describe the
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`document. The Samsung Defendants lack knowledge or information sufficient to form a belief as
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`to the truth of the remaining allegations of Paragraph 37, and therefore deny them.
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`11
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`Case 1:14-cv-01430-LPS Document 313 Filed 07/08/20 Page 12 of 29 PageID #: 21281
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`38.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 38, and therefore deny them.
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`39.
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`The Samsung Defendants aver that the document attached as Exhibit 15 speaks for
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`itself and deny the allegations of Paragraph 39 to the extent they do not accurately describe the
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`document. The Samsung Defendants lack knowledge or information sufficient to form a belief as
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`to the truth of the remaining allegations of Paragraph 39, and therefore deny them.
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`40.
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`The Samsung Defendants aver that the document attached as Exhibit 16 speaks for
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`itself and deny the allegations of Paragraph 40 to the extent they do not accurately describe the
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`document. The Samsung Defendants lack knowledge or information sufficient to form a belief as
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`to the truth of the remaining allegations of Paragraph 40, and therefore deny them.
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`41.
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`The Samsung Defendants aver that the document attached as Exhibit 17 speaks for
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`itself and deny the allegations of Paragraph 41 to the extent they do not accurately describe the
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`document. The Samsung Defendants lack knowledge or information sufficient to form a belief as
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`to the truth of the remaining allegations of Paragraph 41, and therefore deny them.
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`42.
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`The Samsung Defendants aver that the document attached as Exhibit 18 speaks for
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`itself and deny the allegations of Paragraph 42 to the extent they do not accurately describe the
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`document. The Samsung Defendants lack knowledge or information sufficient to form a belief as
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`to the truth of the remaining allegations of Paragraph 42, and therefore deny them.
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`43.
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`The Samsung Defendants aver that the document attached as Exhibit 19 speaks for
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`itself and deny the allegations of Paragraph 43 to the extent they do not accurately describe the
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`document. The Samsung Defendants lack knowledge or information sufficient to form a belief as
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`to the truth of the remaining allegations of Paragraph 43, and therefore deny them.
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`12
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`Case 1:14-cv-01430-LPS Document 313 Filed 07/08/20 Page 13 of 29 PageID #: 21282
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`44.
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`The Samsung Defendants aver that the document attached as Exhibit 20 speaks for
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`itself and deny the allegations of Paragraph 44 to the extent they do not accurately describe the
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`document. The Samsung Defendants lack knowledge or information sufficient to form a belief as
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`to the truth of the remaining allegations of Paragraph 44, and therefore deny them.
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`45.
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`The Samsung Defendants aver that the document attached as Exhibit 20 speaks for
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`itself and deny the allegations of Paragraph 45 to the extent they do not accurately describe the
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`document. The Samsung Defendants lack knowledge or information sufficient to form a belief as
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`to the truth of the remaining allegations of Paragraph 45, and therefore deny them.
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`46.
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`47.
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`48.
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`The Samsung Defendants deny the allegations of Paragraph 46.
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`The Samsung Defendants deny the allegations of Paragraph 47.
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`The Samsung Defendants deny the allegations of Paragraph 48.
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`THE PURPORTED POST-SUIT DIRECT INFRINGEMENT
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`49.
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`The Samsung Defendants aver that the document attached as Exhibit 21 speaks for
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`itself and deny the allegations of Paragraph 49 to the extent they do not accurately describe the
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`document. The Samsung Defendants lack knowledge or information sufficient to form a belief as
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`to the truth of the remaining allegations of Paragraph 49, and therefore deny them.
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`50.
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`The Samsung Defendants aver that the document attached as Exhibit 21 speaks for
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`itself and deny the allegations of Paragraph 50 to the extent they do not accurately describe the
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`document. The Samsung Defendants lack knowledge or information sufficient to form a belief as
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`to the truth of the remaining allegations of Paragraph 50, and therefore deny them.
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`51.
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`52.
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`53.
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`The Samsung Defendants deny the allegations of Paragraph 51.
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`The Samsung Defendants deny the allegations of Paragraph 52.
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`The Samsung Defendants deny the allegations of Paragraph 53.
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`13
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`Case 1:14-cv-01430-LPS Document 313 Filed 07/08/20 Page 14 of 29 PageID #: 21283
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`(The Purported Indirect Infringement)
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`GENERAL ALLEGATIONS
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`The Samsung Defendants deny the allegations of Paragraph 54.
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`The Samsung Defendants deny the allegations of Paragraph 55.
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`The Samsung Defendants deny the allegations of Paragraph 56.
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`The Samsung Defendants deny the allegations of Paragraph 57.
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`The Samsung Defendants deny the allegations of Paragraph 58.
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`The Samsung Defendants deny the allegations of Paragraph 59.
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`THE PURPORTED PRE-SUIT INDIRECT INFRINGEMENT
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`NOTICE OF PATENTS
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`The Samsung Defendants deny the allegations of Paragraph 60.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`54.
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`55.
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`56.
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`57.
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`58.
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`59.
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`60.
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`61.
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`as to the truth of the allegations of Paragraph 61, and therefore deny them.
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`62.
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`63.
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`The Samsung Defendants deny the allegations of Paragraph 62.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations in Paragraph 63, and therefore deny them.
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`(a)
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`The Samsung Defendants admit that they are the assignees of U.S. Patent
`
`No. 8,136,017 and that it was issued on March 13, 2012. The Samsung Defendants admit that
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`U.S. Patent No. 8,136,017 cites to U.S. Patent Nos. 5,915,167; 6,133,640; 6,208,545; and
`
`6,551,857. Except as expressly admitted, the Samsung Defendants lack knowledge or information
`
`sufficient to form a belief as to the truth of the remaining allegations of Paragraph 63(a), and
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`therefore deny them.
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`Case 1:14-cv-01430-LPS Document 313 Filed 07/08/20 Page 15 of 29 PageID #: 21284
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`
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`(b)
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` The Samsung Defendants admit that they are the assignees of U.S. Patent
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`No. 8,031,505 and that it was issued on October 4, 2011. The Samsung Defendants admit that
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`U.S. Patent No. 8,031,505 cites to U.S. Patent No. 6,133,640. Except as expressly admitted, the
`
`Samsung Defendants lack knowledge or information sufficient to form a belief as to the truth of
`
`the remaining allegations of Paragraph 63(b), and therefore deny them.
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`64.
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`The Samsung Defendants aver that the document attached as Exhibit 22 speaks for
`
`itself and deny the allegations of Paragraph 64 to the extent they do not accurately describe the
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`document. The Samsung Defendants lack knowledge or information sufficient to form a belief as
`
`to the truth of the remaining allegations of Paragraph 64, and therefore deny them.
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`65.
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`The Samsung Defendants aver that the document attached as Exhibit 23 speaks for
`
`itself and deny the allegations of Paragraph 65 to the extent they do not accurately describe the
`
`document. The Samsung Defendants lack knowledge or information sufficient to form a belief as
`
`to the truth of the remaining allegations of Paragraph 65, and therefore deny them.
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`66.
`
`The Samsung Defendants lack knowledge or information sufficient to form a belief
`
`as to the truth of the allegations of Paragraph 66, and therefore deny them.
`
`67.
`
`The Samsung Defendants lack knowledge or information sufficient to form a belief
`
`as to the truth of the allegations of Paragraph 67, and therefore deny them.
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`68.
`
`The Samsung Defendants lack knowledge or information sufficient to form a belief
`
`as to the truth of the allegations of Paragraph 68, and therefore deny them.
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`NOTICE OF HOW PRODUCTS INFRINGE
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`69.
`
`70.
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`The Samsung Defendants deny the allegations in Paragraph 69.
`
`The Samsung Defendants deny the allegations in Paragraph 70.
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`Case 1:14-cv-01430-LPS Document 313 Filed 07/08/20 Page 16 of 29 PageID #: 21285
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`
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`71.
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`The Samsung Defendants aver that the document attached as Exhibit 1 speaks for
`
`itself and deny the allegations of Paragraph 71 to the extent they do not accurately describe the
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`document. Except as expressly admitted, the Samsung Defendants deny the remaining allegations
`
`of Paragraph 71 of the SAC.
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`72.
`
`73.
`
`The Samsung Defendants deny the allegations of Paragraph 72.
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`The Samsung Defendants admit that they design, develop, manufacture and provide
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`to the U.S. and world markets a wide range of innovative products, including semiconductors.
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`Except as expressly admitted, the Samsung Defendants lack knowledge or information to form a
`
`belief as to the truth of the remaining allegations of Paragraph 73, and therefore deny them.
`
`74.
`
`75.
`
`The Samsung Defendants deny the allegations of Paragraph 74.
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`The Samsung Defendants aver that the document attached as Exhibit 24 speaks for
`
`itself and deny the allegations of Paragraph 75 to the extent they do not accurately describe the
`
`document. The Samsung Defendants lack knowledge or information sufficient to form a belief as
`
`to the truth of the remaining allegations of Paragraph 75, and therefore deny them.
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`76.
`
`The Samsung Defendants aver that the documents attached as Exhibit 24 and
`
`Exhibit 25 speak for themselves and deny the allegations of Paragraph 76 to the extent they do not
`
`accurately describe the document. The Samsung Defendants lack knowledge or information
`
`sufficient to form a belief as to the truth of the remaining allegations of Paragraph 76, and therefore
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`deny them.
`
`77.
`
`The Samsung Defendants deny the allegations of Paragraph 77.
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`NOTICE OF HOW CUSTOMERS INFRINGE
`
`78.
`
`The Samsung Defendants lack knowledge or information sufficient to form a belief
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`as to the truth of the allegations of Paragraph 78, and therefore deny them.
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`Case 1:14-cv-01430-LPS Document 313 Filed 07/08/20 Page 17 of 29 PageID #: 21286
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`
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`79.
`
`The Samsung Defendants aver that the document attached as Exhibit 26 speaks for
`
`itself and deny the allegations of Paragraph 79 to the extent they do not accurately describe the
`
`document. The Samsung Defendants lack knowledge or information sufficient to form a belief as
`
`to the truth of the remaining allegations of Paragraph 79, and therefore deny them.
`
`80.
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`The Samsung Defendants lack knowledge or information sufficient to form a belief
`
`as to the truth of the allegations of Paragraph 80, and therefore deny them.
`
`81.
`
`82.
`
`The Samsung Defendants deny the allegations of Paragraph 81.
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`The Samsung Defendants deny the allegations of Paragraph 82.
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`ENCOURAGEMENT/SPECIFIC INTENT TO INDUCE THE INFRINGEMENT
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`83.
`
`84.
`
`The Samsung Defendants deny the allegations of Paragraph 83.
`
`The Samsung Defendants aver that the document attached as Exhibit 26 speaks for
`
`itself and deny the allegations of Paragraph 84 to the extent they do not accurately describe the
`
`document. The Samsung Defendants lack knowledge or information sufficient to form a belief as
`
`to the truth of the remaining allegations of Paragraph 84, and therefore deny them.
`
`85.
`
`The Samsung Defendants lack knowledge or information sufficient to form a belief
`
`as to the truth of the remaining allegations of Paragraph 85, and therefore deny them.
`
`86.
`
`87.
`
`88.
`
`89.
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`The Samsung Defendants deny the allegations of Paragraph 86.
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`The Samsung Defendants deny the allegations of Paragraph 87.
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`THE PURPORTED POST-SUIT INDIRECT INFRINGEMENT
`
`NOTICE OF PATENTS
`
`The Samsung Defendants deny the allegations of Paragraph 88.
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`The Samsung Defendants deny the allegations of Paragraph 89.
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`17
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`