throbber
Case 1:21-cv-01445-JPM Document 98 Filed 02/27/23 Page 1 of 13 PageID #: 2274
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`GLOBUS MEDICAL, INC.,
`
`
`C.A. No. 21-1445 (JPM)
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF GLOBUS MEDICAL, INC.’S
`ANSWER TO DEFENDANT LIFE SPINE INC.’S COUNTERCLAIMS
`
`
`
`WEIR GREENBLATT PIERCE LLP
`Jeffrey S. Cianciulli (No. 4369)
`824 Market Street Mall, Suite 800
`Wilmington, DE 19801
`(302) 652-8181
`jcianciulli@wgpllp.com
`
`Attorneys for Plaintiff Globus Medical, Inc.
`
`
`OF COUNSEL:
`
`Arun S. Subramanian
`Jacob Buchdahl
`Mark Hatch-Miller
`Geng Chen
`SUSMAN GODFREY L.L.P.
`1301 Avenue of the Americas, 32nd Fl.
`New York, NY 10019
`(212) 336-8330
`asubramanian@susmangodfrey.com
`jbuchdahl@susmangodfrey.com
`mhatch-miller@susmangodfrey.com
`gchen@susmangodfrey.com
`
`
`
`
`John P. Lahad
`SUSMAN GODFREY L.L.P.
`1000 Louisiana Street, Suite 5100
`Houston, TX 77002-5096
`(713) 653-7859
`jlahad@susmangodfrey.com
`
`
`
`Dated: February 27, 2023
`
`
`
`
`
`
`Plaintiff,
`
`
`LIFE SPINE, INC.,
`
`
`v.
`
`Defendant.
`
`
`
`
`
`
`
`
`
`
`

`

`Case 1:21-cv-01445-JPM Document 98 Filed 02/27/23 Page 2 of 13 PageID #: 2275
`
`Plaintiff Globus Medical, Inc. (“Globus”) by and through counsel, hereby responds to the
`
`numbered paragraphs of Defendant Life Spine, Inc.’s (“Life Spine”) counterclaims for non-
`
`infringement and invalidity (together the “Counterclaims”) of U.S. Patent No. 8,845,731 (the “’731
`
`Patent”), U.S. Patent No. 8,845,732 (the “’732 Patent”), U.S. Patent No. 9,402,739 (the “’739
`
`Patent”), U.S. Patent No. 9,956,087 (the “’087 Patent”), U.S. Patent No. 10,137,001 (the “’001
`
`Patent”), U.S. Patent No. 10,925,752 (the “’752 Patent”), U.S. Patent No. 10,973,649 (the “’649
`
`Patent”), and U.S. Patent No. 11,065,128 (the “’128 Patent”) (together the “Asserted Patents”).
`
`All averments and allegations not expressly admitted herein are denied.
`
`PARTIES
`
`Admitted.
`
`Admitted.
`
`JURISDICTION AND VENUE
`
`Paragraph 3 purports to characterize the Counterclaims, a legal document which
`
`1.
`
`2.
`
`3.
`
`speaks for itself, and therefore no response is required.
`
`4.
`
`Paragraph 4 states legal conclusions to which no response is required. Globus
`
`does not contest that the Court has subject matter jurisdiction over these Counterclaims.
`
`5.
`
`Paragraph 5 states legal conclusions to which no response is required. Globus
`
`does not contest that the Court has personal jurisdiction over it for the purposes of this action.
`
`6.
`
`Paragraph 6 states legal conclusions to which no response is required, except that
`
`Globus admits it filed this action in the District of Delaware.
`
`FIRST COUNTERCLAIM
`DECLARATION OF NON-INFRINGEMENT OF THE ’731 PATENT
`
`7.
`
`Globus incorporates its responses to each and every allegation set forth above in
`
`these Counterclaims as if fully stated herein. To the extent Paragraph 7 repeats and alleges the
`
`
`
`1
`
`

`

`Case 1:21-cv-01445-JPM Document 98 Filed 02/27/23 Page 3 of 13 PageID #: 2276
`
`“responses” in Life Spine’s Answer, no response is required.
`
`8.
`
`9.
`
`Admitted.
`
`Admitted.
`
`10.
`
`Globus admits that the Second Amended Complaint alleges that Life Spine
`
`infringes at least Claim 1 of the ’731 Patent. The remainder of Paragraph 10 states legal
`
`conclusions to which no response is required. To the extent the remainder of Paragraph 10
`
`contains any factual allegations, they are denied.
`
`11.
`
`Paragraph 11 states legal conclusions to which no response is required. To the
`
`extent Paragraph 11 contains any factual allegations, they are denied.
`
`12.
`
`Paragraph 12 states legal conclusions to which no response is required. Globus
`
`denies that Life Spine is entitled to the relief requested. To the extent Paragraph 12 contains any
`
`factual allegations, they are denied.
`
`SECOND COUNTERCLAIM
`DECLARATION OF NON-INFRINGEMENT OF THE ’723 PATENT
`
`13.
`
`Globus incorporates its responses to each and every allegation set forth above in
`
`these Counterclaims as if fully stated herein. To the extent Paragraph 13 repeats and alleges the
`
`“responses” in Life Spine’s Answer, no response is required.
`
`14.
`
`15.
`
`16.
`
`Admitted.
`
`Admitted.
`
`Globus admits that the Second Amended Complaint alleges that Life Spine
`
`infringes at least Claim 1 of the ’732 Patent. The remainder of Paragraph 16 states legal
`
`conclusions to which no response is required. To the extent the remainder of Paragraph 16
`
`contains any factual allegations, they are denied.
`
`17.
`
`Paragraph 17 states legal conclusions to which no response is required. To the
`
`
`
`2
`
`

`

`Case 1:21-cv-01445-JPM Document 98 Filed 02/27/23 Page 4 of 13 PageID #: 2277
`
`extent Paragraph 17 contains any factual allegations, they are denied.
`
`18.
`
`Paragraph 18 states legal conclusions to which no response is required. Globus
`
`denies that Life Spine is entitled to the relief requested. To the extent Paragraph 18 contains any
`
`factual allegations, they are denied.
`
`THIRD COUNTERCLAIM
`DECLARATION OF NON-INFRINGEMENT FO THE ’739 PATENT
`
`19.
`
`Globus incorporates its responses to each and every allegation set forth above in
`
`these Counterclaims as if fully stated herein. To the extent Paragraph 19 repeats and alleges the
`
`“responses” in Life Spine’s Answer, no response is required.
`
`20.
`
`21.
`
`22.
`
`Admitted.
`
`Admitted.
`
`Globus admits that the Second Amended Complaint alleges that Life Spine
`
`infringes at least Claim 1 of the ’739 Patent. The remainder of Paragraph 22 states legal
`
`conclusions to which no response is required. To the extent the remainder of Paragraph 22
`
`contains any factual allegations, they are denied.
`
`23.
`
`Paragraph 23 states legal conclusions to which no response is required. To the
`
`extent Paragraph 17 contains any factual allegations, they are denied.
`
`24.
`
`Paragraph 24 states legal conclusions to which no response is required. Globus
`
`denies that Life Spine is entitled to the relief requested. To the extent Paragraph 24 contains any
`
`factual allegations, they are denied.
`
`FOURTH COUNTERCLAIM
`DECLARATION OF NON-INFRINGEMENT OF THE ’087 PATENT
`
`25.
`
`Globus incorporates its responses to each and every allegation set forth above in
`
`these Counterclaims as if fully stated herein. To the extent Paragraph 25 repeats and alleges the
`
`
`
`3
`
`

`

`Case 1:21-cv-01445-JPM Document 98 Filed 02/27/23 Page 5 of 13 PageID #: 2278
`
`“responses” in Life Spine’s Answer, no response is required.
`
`26.
`
`27.
`
`28.
`
`Admitted.
`
`Admitted.
`
`Globus admits that the Second Amended Complaint alleges that Life Spine
`
`infringes at least Claim 1 of the ’087 Patent. The remainder of Paragraph 28 states legal
`
`conclusions to which no response is required. To the extent the remainder of Paragraph 28
`
`contains any factual allegations, they are denied.
`
`29.
`
`Paragraph 29 states legal conclusions to which no response is required. To the
`
`extent Paragraph 29 contains any factual allegations, they are denied.
`
`30.
`
`Paragraph 30 states legal conclusions to which no response is required. Globus
`
`denies that Life Spine is entitled to the relief requested. To the extent Paragraph 30 contains any
`
`factual allegations, they are denied.
`
`FIFTH COUNTERCLAIM
`DECLARATION OF NON-INFRINGEMENT OF THE ’001 PATENT
`
`31.
`
`Globus incorporates its responses to each and every allegation set forth above in
`
`these Counterclaims as if fully stated herein. To the extent Paragraph 31 repeats and alleges the
`
`“responses” in Life Spine’s Answer, no response is required.
`
`32.
`
`33.
`
`34.
`
`Admitted.
`
`Admitted.
`
`Globus admits that the Second Amended Complaint alleges that Life Spine
`
`infringes at least Claim 1 of the ’001 Patent. The remainder of Paragraph 34 states legal
`
`conclusions to which no response is required. To the extent the remainder of Paragraph 34
`
`contains any factual allegations, they are denied.
`
`35.
`
`Paragraph 35 states legal conclusions to which no response is required. To the
`
`
`
`4
`
`

`

`Case 1:21-cv-01445-JPM Document 98 Filed 02/27/23 Page 6 of 13 PageID #: 2279
`
`extent Paragraph 35 contains any factual allegations, they are denied.
`
`36.
`
`Paragraph 36 states legal conclusions to which no response is required. Globus
`
`denies that Life Spine is entitled to the relief requested. To the extent Paragraph 36 contains any
`
`factual allegations, they are denied.
`
`SIXTH COUNTERCLAIM
`DECLARATION OF NON-INFRINGEMENT OF THE ’752 PATENT
`
`37.
`
`Globus incorporates its responses to each and every allegation set forth above in
`
`these Counterclaims as if fully stated herein. To the extent Paragraph 37 repeats and alleges the
`
`“responses” in Life Spine’s Answer, no response is required.
`
`38.
`
`39.
`
`40.
`
`Admitted.
`
`Admitted.
`
`Globus admits that the Second Amended Complaint alleges that Life Spine
`
`infringes at least Claim 1 of the ’752 Patent. The remainder of Paragraph 40 states legal
`
`conclusions to which no response is required. To the extent the remainder of Paragraph 40
`
`contains any factual allegations, they are denied.
`
`41.
`
`Paragraph 41 states legal conclusions to which no response is required. To the
`
`extent Paragraph 41 contains any factual allegations, they are denied.
`
`42.
`
`Paragraph 42 states legal conclusions to which no response is required. Globus
`
`denies that Life Spine is entitled to the relief requested. To the extent Paragraph 42 contains any
`
`factual allegations, they are denied.
`
`SEVENTH COUNTERCLAIM
`DECLARATION OF NON-INFRINGEMENT OF THE ’649 PATENT
`
`43.
`
`Globus incorporates its responses to each and every allegation set forth above in
`
`these Counterclaims as if fully stated herein. To the extent Paragraph 43 repeats and alleges the
`
`
`
`5
`
`

`

`Case 1:21-cv-01445-JPM Document 98 Filed 02/27/23 Page 7 of 13 PageID #: 2280
`
`“responses” in Life Spine’s Answer, no response is required.
`
`44.
`
`45.
`
`46.
`
`Admitted.
`
`Admitted.
`
`Globus admits that the Second Amended Complaint alleges that Life Spine
`
`infringes at least Claim 1 of the ’649 Patent. The remainder of Paragraph 46 states legal
`
`conclusions to which no response is required. To the extent the remainder of Paragraph 46
`
`contains any factual allegations, they are denied.
`
`47.
`
`Paragraph 47 states legal conclusions to which no response is required. To the
`
`extent Paragraph 47 contains any factual allegations, they are denied.
`
`48.
`
`Paragraph 48 states legal conclusions to which no response is required. Globus
`
`denies that Life Spine is entitled to the relief requested. To the extent Paragraph 48 contains any
`
`factual allegations, they are denied.
`
`EIGHTH COUNTERCLAIM
`DECLARATION OF NON-INFRINGEMENT OF THE ’128 PATENT
`
`49.
`
`Globus incorporates its responses to each and every allegation set forth above in
`
`these Counterclaims as if fully stated herein. To the extent Paragraph 49 repeats and alleges the
`
`“responses” in Life Spine’s Answer, no response is required.
`
`50.
`
`51.
`
`52.
`
`Admitted.
`
`Admitted.
`
`Globus admits that the Second Amended Complaint alleges that Life Spine
`
`infringes at least Claim 1 of the ’128 Patent. The remainder of Paragraph 52 states legal
`
`conclusions to which no response is required. To the extent the remainder of Paragraph 52
`
`contains any factual allegations, they are denied.
`
`53.
`
`Paragraph 53 states legal conclusions to which no response is required. To the
`
`
`
`6
`
`

`

`Case 1:21-cv-01445-JPM Document 98 Filed 02/27/23 Page 8 of 13 PageID #: 2281
`
`extent Paragraph 53 contains any factual allegations, they are denied.
`
`54.
`
`Paragraph 54 states legal conclusions to which no response is required. Globus
`
`denies that Life Spine is entitled to the relief requested. To the extent Paragraph 54 contains any
`
`factual allegations, they are denied.
`
`NINTH COUNTERCLAIM
`DECLARATION OF INVALIDITY OF THE ’731 PATENT
`
`55.
`
`Globus incorporates its responses to each and every allegation set forth above in
`
`these Counterclaims as if fully stated herein. To the extent Paragraph 55 repeats and alleges the
`
`“responses” in Life Spine’s Answer, no response is required.
`
`56.
`
`Paragraph 56 states legal conclusions to which no response is required. To the
`
`extent Paragraph 56 contains any factual allegations, they are denied.
`
`57.
`
`Paragraph 57 states legal conclusions to which no response is required. Globus
`
`denies that Life Spine is entitled to the relief requested. To the extent Paragraph 57 contains any
`
`factual allegations, they are denied.
`
`TENTH COUNTERCLAIM
`DECLARATION OF INVALIDITY OF THE ’732 PATENT
`
`58.
`
`Globus incorporates its responses to each and every allegation set forth above in
`
`these Counterclaims as if fully stated herein. To the extent Paragraph 58 repeats and alleges the
`
`“responses” in Life Spine’s Answer, no response is required.
`
`59.
`
`Paragraph 59 states legal conclusions to which no response is required. To the
`
`extent Paragraph 59 contains any factual allegations, they are denied.
`
`60.
`
`Paragraph 60 states legal conclusions to which no response is required. Globus
`
`denies that Life Spine is entitled to the relief requested. To the extent Paragraph 60 contains any
`
`factual allegations, they are denied.
`
`
`
`7
`
`

`

`Case 1:21-cv-01445-JPM Document 98 Filed 02/27/23 Page 9 of 13 PageID #: 2282
`
`ELEVENTH COUNTERCLAIM
`DECLARATION OF INVALIDITY OF THE ’739 PATENT
`
`61.
`
`Globus incorporates its responses to each and every allegation set forth above in
`
`these Counterclaims as if fully stated herein. To the extent Paragraph 61 repeats and alleges the
`
`“responses” in Life Spine’s Answer, no response is required.
`
`62.
`
`Paragraph 62 states legal conclusions to which no response is required. To the
`
`extent Paragraph 62 contains any factual allegations, they are denied.
`
`63.
`
`Paragraph 63 states legal conclusions to which no response is required. Globus
`
`denies that Life Spine is entitled to the relief requested. To the extent Paragraph 63 contains any
`
`factual allegations, they are denied.
`
`TWELFTH COUNTERCLAIM
`DECLARATION OF INVALIDITY OF THE ’087 PATENT
`
`64.
`
`Globus incorporates its responses to each and every allegation set forth above in
`
`these Counterclaims as if fully stated herein. To the extent Paragraph 64 repeats and alleges the
`
`“responses” in Life Spine’s Answer, no response is required.
`
`65.
`
`Paragraph 65 states legal conclusions to which no response is required. To the
`
`extent Paragraph 65 contains any factual allegations, they are denied.
`
`66.
`
`Paragraph 66 states legal conclusions to which no response is required. Globus
`
`denies that Life Spine is entitled to the relief requested. To the extent Paragraph 66 contains any
`
`factual allegations, they are denied.
`
`THIRTEENTH COUNTERCLAIM
`DECLARATION OF INVALIDITY OF THE ’001 PATENT
`
`67.
`
`Globus incorporates its responses to each and every allegation set forth above in
`
`these Counterclaims as if fully stated herein. To the extent Paragraph 67 repeats and alleges the
`
`“responses” in Life Spine’s Answer, no response is required.
`
`
`
`8
`
`

`

`Case 1:21-cv-01445-JPM Document 98 Filed 02/27/23 Page 10 of 13 PageID #: 2283
`
`68.
`
`Paragraph 68 states legal conclusions to which no response is required. To the
`
`extent Paragraph 68 contains any factual allegations, they are denied.
`
`69.
`
`Paragraph 69 states legal conclusions to which no response is required. Globus
`
`denies that Life Spine is entitled to the relief requested. To the extent Paragraph 69 contains any
`
`factual allegations, they are denied.
`
`FOURTEENTH COUNTERCLAIM
`DECLARATION OF INVALIDITY OF THE ’752 PATENT
`
`70.
`
`Globus incorporates its responses to each and every allegation set forth above in
`
`these Counterclaims as if fully stated herein. To the extent Paragraph 70 repeats and alleges the
`
`“responses” in Life Spine’s Answer, no response is required.
`
`71.
`
`Paragraph 71 states legal conclusions to which no response is required. To the
`
`extent Paragraph 71 contains any factual allegations, they are denied.
`
`72.
`
`Paragraph 72 states legal conclusions to which no response is required. Globus
`
`denies that Life Spine is entitled to the relief requested. To the extent Paragraph 72 contains any
`
`factual allegations, they are denied.
`
`FIFTEENTH COUNTERCLAIM
`DECLARATION OF INVALIDITY OF THE ’649 PATENT
`
`73.
`
`Globus incorporates its responses to each and every allegation set forth above in
`
`these Counterclaims as if fully stated herein. To the extent Paragraph 73 repeats and alleges the
`
`“responses” in Life Spine’s Answer, no response is required.
`
`74.
`
`Paragraph 74 states legal conclusions to which no response is required. To the
`
`extent Paragraph 74 contains any factual allegations, they are denied.
`
`75.
`
`Paragraph 75 states legal conclusions to which no response is required. Globus
`
`denies that Life Spine is entitled to the relief requested. To the extent Paragraph 75 contains any
`
`
`
`9
`
`

`

`Case 1:21-cv-01445-JPM Document 98 Filed 02/27/23 Page 11 of 13 PageID #: 2284
`
`factual allegations, they are denied.
`
`SIXTEENTH COUNTERCLAIM
`DECLARATION OF INVALIDITY OF THE ’128 PATENT
`
`76.
`
`Globus incorporates its responses to each and every allegation set forth above in
`
`these Counterclaims as if fully stated herein. To the extent Paragraph 76 repeats and alleges the
`
`“responses” in Life Spine’s Answer, no response is required.
`
`77.
`
`Paragraph 77 states legal conclusions to which no response is required. To the
`
`extent Paragraph 77 contains any factual allegations, they are denied.
`
`78.
`
`Paragraph 78 states legal conclusions to which no response is required. Globus
`
`denies that Life Spine is entitled to the relief requested. To the extent Paragraph 78 contains any
`
`factual allegations, they are denied.
`
`PRAYER FOR RELIEF
`
`Globus denies that Life Spine is entitled to any of the requested relief prayed for in its
`
`Counterclaims. Globus respectfully requests that the Court deny all such relief with prejudice and
`
`enter judgment in Globus’s favor as follows:
`
`A.
`
`B.
`
`C.
`
`D.
`
`E.
`
`F.
`
`G.
`
`A declaration that Life Spine has willfully infringed each of the Asserted Patents.
`
`A permanent injunction prohibiting Life Spine from infringing the Asserted
`
`Patents.
`
`A declaration that each of the Asserted Patents in valid and enforceable.
`
`An award of damages to Globus including enhanced damages pursuant to 35 U.S.C.
`
`§ 284.
`
`An award of attorneys’ fees to Globus pursuant to 35 U.S.C. § 285.
`
`An award of expenses and costs incurred by Globus in connection with this action.
`
`An award to Globus of pre-judgment and post-judgment interest.
`
`
`
`10
`
`

`

`Case 1:21-cv-01445-JPM Document 98 Filed 02/27/23 Page 12 of 13 PageID #: 2285
`
`H.
`
`I.
`
`Dismissal of Life Spine’s Counterclaims with prejudice.
`
`An award to Globus of any other relief that the Court deems just and proper.
`
`DEMAND FOR JURY TRIAL
`
`Globus demands a jury trial for all issues so triable.
`
`GENERAL DENIAL
`
`Globus denies each and every allegation in the Counterclaims that has not been admitted
`
`or responded to specifically. To the extent any factual allegations remain unanswered, they are
`
`denied. Globus further denies that Life Spine is entitled to any of the relief sought in the
`
`Counterclaims.
`
`AFFIRMATIVE DEFENSE
`
`Globus hereby asserts the following affirmative defense to Life Spine’s Counterclaims. On
`
`September 20, 2022, Life Spine stipulated it would not pursue in this action any ground raised or
`
`that could have been reasonably raised in any petition filed by Life Spine for inter partes review
`
`of the Asserted Patents should the Patent Trial and Appeal Board institute review. To the extent
`
`the PTAB institutes any such review, Life Spine’s Ninth through Sixteenth Counterclaims are
`
`barred by 35 U.S.C. § 315(e)(2) and the doctrines of estoppel and waiver to the extent that they
`
`assert grounds that were raised or could have been raised in such review.
`
`Globus further reserves the right to amend this answer and assert any additional defenses
`
`of which it may become aware.
`
`Dated: February 27, 2023
`
`
`OF COUNSEL:
`
`Arun S. Subramanian
`Jacob Buchdahl
`Mark Hatch-Miller
`Geng Chen
`
`WEIR GREENBLATT PIERCE LLP
`
`/s/ Jeffrey S. Cianciulli
`Jeffrey S. Cianciulli (No. 4369)
`824 Market Street Mall, Suite 800
`Wilmington, DE 19801
`
`
`
`
`
`11
`
`

`

`Case 1:21-cv-01445-JPM Document 98 Filed 02/27/23 Page 13 of 13 PageID #: 2286
`
`SUSMAN GODFREY L.L.P.
`1301 Avenue of the Americas, 32nd Fl.
`New York, NY 10019
`(212) 336-8330
`asubramanian@susmangodfrey.com
`jbuchdahl@susmangodfrey.com
`mhatch-miller@susmangodfrey.com
`gchen@susmangodfrey.com
`
`
`
`
`John P. Lahad
`SUSMAN GODFREY L.L.P.
`1000 Louisiana Street, Suite 5100
`Houston, TX 77002-5096
`(713) 653-7859
`jlahad@susmangodfrey.com
`
`
`
`
`
`
`
`
`(302) 652-8181
`jcianciulli@wgpllp.com
`
`Attorneys for Plaintiff Globus Medical, Inc.
`
`
`
`
`12
`
`

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