Case 1:23-cv-01237-GBW Document 11 Filed 12/11/23 Page 1 of 83 PageID #: 1835
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`IN THE UNITED STATES DISTRICT COURT
`DISTRICT OF DELAWARE
`
`NOKIA TECHNOLOGIES OY,
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`Plaintiff/Counterclaim Defendant,
`
`v.
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`HP, INC.,
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`Defendant/Counterclaim Plaintiff.
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`C.A. No. 23-cv-1237-GBW
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`JURY TRIAL DEMANDED
`
`DEFENDANT/COUNTERCLAIM PLAINTIFF HP INC.’S
`ORIGINAL ANSWER TO PLAINTIFF’S ORIGINAL COMPLAINT, AND ORIGINAL
`COUNTERCLAIMS
`
`Defendant HP Inc. (“HP”), by and through its attorneys, hereby submits its Answer,
`
`Defenses, and Counterclaims to the Complaint filed by Plaintiff Nokia Technologies Oy
`
`(“Nokia”). The paragraph numbers in this Answer correspond to the paragraph numbers in the
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`Complaint. For convenience and clarity, HP will also use the same headings as set forth in the
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`Complaint. In doing so, HP does not admit any of the allegations contained in Nokia’s headings.
`
`All allegations of the Complaint not expressly admitted in this Answer are denied.
`
`NATURE OF THE ACTION
`
`1.
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`HP admits that the H.264 and H.265 Standards are promulgated by the
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`International Telecommunications Union (“ITU”). HP admits that Nokia has submitted
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`declarations that its patent portfolio includes claims essential to decoding video according to the
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`H.264 and/or H.265 Standards. HP denies that Nokia has established that any claims of the
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`Asserted Patents are, in fact, essential for compliance with the H.264 and H.265 Standards. HP
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`1
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`Case 1:23-cv-01237-GBW Document 11 Filed 12/11/23 Page 2 of 83 PageID #: 1836
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`lacks knowledge or information sufficient to form a belief as to the truth of the remaining
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`allegations in Paragraph 1, and therefore denies them.
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`2.
`
`3.
`
`Denied.
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`HP lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations in Paragraph 3, and therefore denies them.
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`4.
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`HP denies that Nokia has established that claims of the Asserted Patents are
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`essential for compliance with the H.264 and H.265 Standards. HP admits that Nokia has
`
`submitted declarations that its patent portfolio includes claims essential to decoding video
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`according to the H.264 and/or H.265 Standards. HP lacks knowledge or information sufficient to
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`form a belief as to the truth of the remaining allegations in Paragraph 4, and therefore denies
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`them.
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`5.
`
`6.
`
`Denied.
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`HP lacks knowledge or information sufficient to form a belief as to the truth of
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`the first sentence of Paragraph 6, and therefore denies the allegations therein. The remaining
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`allegations in Paragraph 6 are denied.
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`PARTIES
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`7.
`
`HP lacks knowledge or information sufficient to form a belief as to the truth of
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`the allegations in Paragraph 7, and therefore denies them.
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`8.
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`HP admits that it is a Delaware corporation with a principal place of business
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`located at 1501 Page Mill Road, Palo Alto, CA 94304.
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`JURISDICTION AND VENUE
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`9.
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`The allegations in Paragraph 9 are conclusions of law to which no response is
`
`required, and they are therefore deemed denied.
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`2
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`

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`10.
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`HP lacks knowledge or information sufficient to form a belief as to the truth of
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`the second sentence of Paragraph 10, and therefore denies it. HP admits that it is a Delaware
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`corporation with a principal place of business in California. The remaining allegations in
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`Paragraph 10 state a conclusion of law to which no response is required, and they are therefore
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`deemed denied. To the extent that a response may be required, HP does not contest, for purposes
`
`of this case only, that this Court has federal jurisdiction over the case.
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`11.
`
`HP lacks knowledge or information sufficient to form a belief as to the truth of
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`the allegations in Paragraph 11, and therefore denies them.
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`12.
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`The allegations of Paragraph 12 are conclusions of law to which no response is
`
`required, and they are therefore deemed denied.
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`13.
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`HP denies that it “has committed acts of infringement in this District.” The
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`remaining allegations in Paragraph 13 state a conclusion of law to which no response is required.
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`To the extent that a response may be required, HP does not contest, for purposes of this case
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`only, that this Court has personal jurisdiction over HP.
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`14.
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`HP admits that it has appointed The Corporation Trust Company, Corporation
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`Trust Center, 1209 Orange St., Wilmington, DE 19801 as a registered agent for service of
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`process. The remaining allegations in Paragraph 14 state a conclusion of law to which no
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`response is required, and they are deemed denied. To the extent that a response may be required,
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`HP does not contest, for purposes of this case only, that this Court has personal jurisdiction over
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`HP.
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`15.
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`The allegations of Paragraph 15 set forth conclusions of law to which no response
`
`is required, and they are deemed denied. To the extent that a response may be required, HP does
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`not contest, for purposes of this case only, that venue is proper in this District.
`
`3
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`

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`Case 1:23-cv-01237-GBW Document 11 Filed 12/11/23 Page 4 of 83 PageID #: 1838
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`NOKIA’S INVESTMENT IN VIDEO CODING STANDARDS AND RESULTING
`PATENTS
`HP lacks knowledge or information sufficient to form a belief as to the truth of
`
`16.
`
`the allegations in Paragraph 16, and therefore denies them.
`
`17.
`
`HP admits that, in early 1998, the ITU’s Telecommunication Standardization
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`Sector (ITU-T) Video Coding Experts Group (VCEG) issued a call for proposals on a project it
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`called H.26L. HP lacks knowledge or information sufficient to form a belief as to the truth of the
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`remaining allegations in Paragraph 17, and therefore denies them.
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`18.
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`HP admits that the ITU has published “ITU-T Recommendation H.264” and
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`“ITU-T Recommendation H.265.” HP lacks knowledge or information sufficient to form a belief
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`as to the truth of the remaining allegations in Paragraph 18, and therefore denies them.
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`19.
`
`HP admits that internet traffic has evolved in recent decades, and video use has
`
`increased. HP lacks knowledge or information sufficient to form a belief as to the truth of the
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`remaining allegations in Paragraph 19, and therefore denies them.
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`20.
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`HP states that “ITU-T Recommendation H.264” and “ITU-T Recommendation
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`H.265” speak for themselves and denies the allegations in Paragraph 20 to the extent inconsistent
`
`therewith. HP lacks knowledge or information sufficient to form a belief as to the truth of the
`
`remaining allegations in Paragraph 20, and therefore denies them.
`
`21.
`
`HP states that “ITU-T Recommendation H.264” speaks for itself and denies the
`
`allegations in Paragraph 21 to the extent inconsistent therewith. HP lacks knowledge or
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`information sufficient to form a belief as to the truth of the remaining allegations in Paragraph
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`21, and therefore denies them.
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`22.
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`HP states that “ITU-T Recommendation H.265” speaks for itself and denies the
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`allegations in Paragraph 22 to the extent inconsistent therewith. HP lacks knowledge or
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`4
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`

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`information sufficient to form a belief as to the truth of the remaining allegations in Paragraph
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`22, and therefore denies them.
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`23.
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`HP lacks knowledge or information sufficient to form a belief as to the truth of
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`the allegations in Paragraph 23, and therefore denies them.
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`24.
`
`HP denies that Nokia has established that the Asserted Patents are patents with
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`standard essential claims relating to the H.264 and H265 Standards. HP lacks knowledge or
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`information sufficient to form a belief as to the truth of the remaining allegations in Paragraph
`
`24, and therefore denies them.
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`NOKIA’S COMPLIANCE WITH THE ITU COMMON PATENT POLICY AND
`NOKIA’S RELEVANT DECLARATIONS
`
`A.
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`25.
`
`The ITU and the H.264 and H.265 Standardization Process
`
`HP lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations in Paragraph 25, and therefore denies them.
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`26.
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`HP admits that the ITU has published “ITU-T Recommendation H.264” and that
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`“the H.264 Standard” exists. HP lacks knowledge or information sufficient to form a belief as to
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`the truth of the allegations in Paragraph 26, and therefore denies them.
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`27.
`
`HP admits that the H.265 Standard was developed after development of the H.264
`
`Standard and is titled “High efficiency video coding.” HP otherwise lacks knowledge or
`
`information sufficient to form a belief as to the truth of the allegations in Paragraph 27, and
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`therefore denies them.
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`28.
`
`HP lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations in Paragraph 28, and therefore denies them.
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`29.
`
`HP lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations in Paragraph 29, and therefore denies them.
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`5
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`

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`Case 1:23-cv-01237-GBW Document 11 Filed 12/11/23 Page 6 of 83 PageID #: 1840
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`30.
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`HP admits that the ITU has a “Common Patent Policy.” The terms of the
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`Common Patent Policy and the obligations resulting therefrom speak for themselves. HP lacks
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`knowledge or information sufficient to form a belief as to the truth of the remaining allegations
`
`in Paragraph 30, and therefore denies them.
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`31.
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`HP admits that the ITU, International Organization for Standardization, and the
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`International Electrotechnical Commission published “Guidelines for Implementation of the
`
`Common Patent Policy for ITU-T/ITU-R/ISO/IEC” in December 2022. The Guidelines speak for
`
`themselves and HP denies the allegations in Paragraph 31 to the extent inconsistent therewith.
`
`HP denies that a document entitled “Guidelines for Implementation of the Common Patent
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`Policy for ITUT/ITURIISOIIEC” is available at
`
`https://www.itu.int/itudoc/itut/patents/policy/guide.pdf. HP lacks knowledge or information
`
`sufficient to form a belief as to the truth of the remaining allegations in Paragraph 31, and
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`therefore denies them.
`
`32.
`
`HP states that “Guidelines for Implementation of the Common Patent Policy for
`
`ITU-T/ITU-R/ISO/IEC” speaks for itself and denies the allegations in Paragraph 32 to the extent
`
`inconsistent therewith. HP denies that a document entitled is available at “Common Patent Policy
`
`for ITU-TIITU-RIISOIIEC” https://www.itu.int/en/ITUT/ipr/Pages/policy.aspx.
`
`33.
`
`HP states that “Guidelines for Implementation of the Common Patent Policy for
`
`ITU-T/ITU-R/ISO/IEC” and the “Patent Statement and Licensing Declaration Form” speak for
`
`themselves and denies the allegations in Paragraph 33 to the extent inconsistent therewith. HP
`
`lacks knowledge or information sufficient to form a belief as to the truth of the remaining
`
`allegations in Paragraph 33, and therefore denies them.
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`6
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`

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`Case 1:23-cv-01237-GBW Document 11 Filed 12/11/23 Page 7 of 83 PageID #: 1841
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`34.
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`HP states that “ITU-T Recommendation H.264” (“the H.264 Standard”) speaks
`
`for itself and denies the allegations in Paragraph 34 to the extent inconsistent therewith.
`
`35.
`
`HP states that “ITU-T Recommendation H.265” (“the H.265 Standard”) speaks
`
`for itself and denies the allegations in Paragraph 35 to the extent inconsistent therewith.
`
`B.
`
`36.
`
`Nokia’s Compliance with the ITU Common Patent Policy and Nokia’s
`Relevant Declarations
`HP denies that Nokia has established that claims of the Asserted Patents are
`
`essential for compliance with the H.264 and H.265 Standards. HP admits that Nokia has
`
`submitted declarations that its patent portfolio includes claims essential to decoding video
`
`according to the H.264 and/or H.265 Standards. HP lacks knowledge or information sufficient to
`
`form a belief as to the truth of the remaining allegations in Paragraph 36, and therefore denies
`
`them.
`
`37.
`
`HP admits that Nokia has filed declarations in which it committed that it is
`
`prepared to grant a license to an unrestricted number of applicants on a worldwide, non-
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`discriminatory basis and on reasonable terms and conditions to make, use and sell
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`implementations of the H.264 and/or H.265 Standard, subject to reciprocity. HP otherwise lacks
`
`knowledge or information sufficient to form a belief as to the truth of the remaining allegations
`
`in Paragraph 37, and therefore denies them.
`
`38.
`
`HP admits that Nokia Corporation submitted Patent Statement and Licensing
`
`Declarations to the ITU, which speak for themselves. HP denies that these declarations were
`
`timely submitted and denies that Nokia complied with the ITU Common Patent Policy. HP lacks
`
`knowledge or information sufficient to form a belief as to the truth of the remaining allegations
`
`in Paragraph 38, and therefore denies them.
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`7
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`

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`C.
`
`39.
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`Nokia’s Negotiations with HP
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`HP admits Nokia has been negotiating with HP since 2019 regarding patents that
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`Nokia contends are essential to the H.264 and H.265 Standards, and that the parties have not
`
`reached an agreement. HP lacks knowledge or information sufficient to form a belief as to the
`
`truth of the allegation in Paragraph 39 that “Nokia made offers to HP consistent with licenses
`
`agreed to by over 50 companies,” and therefore denies it. The remaining allegations of Paragraph
`
`39 are denied.
`
`40.
`
`HP admits that Nokia contacted HP in November 2019 regarding patents that
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`Nokia contends are related to the H.264 standard. HP admits that Nokia proposed that the parties
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`enter into a non-disclosure agreement. HP admits that Nokia delivered a presentation to HP on
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`March 12, 2020, which speaks for itself. HP lacks knowledge or information sufficient to form a
`
`belief as to the truth of the remaining allegations in Paragraph 40, and therefore denies them.
`
`41.
`
`HP admits that on July 22, 2020, Nokia sent documentation to HP. The
`
`documents speak for themselves, and HP denies the allegations in Paragraph 41 to the extent
`
`inconsistent therewith. HP denies that any of its products are infringing products. The remaining
`
`allegations in Paragraph 41 are denied.
`
`42.
`
`HP admits that it executed an NDA with Nokia on December 8, 2020. HP admits
`
`that after the execution of the NDA, Nokia sent HP a license offer, terms and conditions, and
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`requested a call. Those documents speak for themselves, and HP denies the allegations in
`
`Paragraph 42 to the extent inconsistent therewith. HP lacks knowledge or information sufficient
`
`to form a belief as to the truth of the remaining allegations in Paragraph 42, and therefore denies
`
`them.
`
`8
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`

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`43.
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`HP admits that representatives of the parties spoke by phone on January 15, 2021.
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`HP admits that, thereafter, Nokia provided additional documentation to HP. Those documents
`
`speak for themselves, and HP denies the allegations in Paragraph 43 to the extent inconsistent
`
`therewith. Otherwise, denied.
`
`44.
`
`HP admits that on May 13, 2021, Nokia sent additional documentation and license
`
`offers to HP. Those documents speak for themselves, and HP denies the allegations in Paragraph
`
`44 to the extent inconsistent therewith. Otherwise, denied.
`
`45.
`
`HP admits that on July 9, 2021, Nokia sent additional documentation to HP.
`
`Those documents speak for themselves, and HP denies the allegations in Paragraph 45 to the
`
`extent inconsistent therewith. Otherwise, denied.
`
`46.
`
`HP admits that on August 13, 2021, Nokia extended offers to HP for patents that
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`Nokia contends relate to encoding video into H.265-compliant formats and decoding
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`H.265-compliant video at different rates. HP lacks knowledge or information sufficient to form a
`
`belief as to the truth of the remaining allegations in Paragraph 46, and therefore denies them.
`
`47.
`
`HP denies that it infringes or has infringed Nokia’s Asserted Patents. HP admits
`
`that on August 27, September 28 and October 1, 2021, Nokia sent additional documentation to
`
`HP. Those documents speak for themselves, and HP denies the allegations in Paragraph 47 to the
`
`extent inconsistent therewith.
`
`48.
`
`HP admits that between January and March 2022, the parties met seven times and
`
`engaged in discussions about Nokia’s patents. HP admits that, thereafter, Nokia sent HP a lump
`
`sum offer for Nokia patent claims. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the remaining allegations in Paragraph 48, and therefore denies them.
`
`9
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`

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`49.
`
`HP admits that it has not accepted Nokia’s offers. HP also admits it has not paid
`
`Nokia a royalty. Otherwise, denied.
`
`50.
`
`Denied.
`
`THE NOKIA ASSERTED PATENTS
`
`51.
`
`HP lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations in Paragraph 51, and therefore denies them. To the extent the allegations in
`
`Paragraph 51 are conclusions of law, no response is required, and they are therefore deemed
`
`denied.
`
`A.
`
`U.S. Patent No. 7,532,808 (“the ’808 Patent”)
`
`52.
`
`53.
`
`Admitted.
`
`The ’808 Patent speaks for itself, and HP denies the allegations in Paragraph 53 to
`
`the extent inconsistent therewith. Otherwise, denied.
`
`54.
`
`The ’808 Patent speaks for itself, and HP denies the allegations in Paragraph 54 to
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`the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the remaining allegations in Paragraph 54, and therefore denies them.
`
`55.
`
`The ’808 Patent speaks for itself, and HP denies the allegations in Paragraph 55 to
`
`the extent inconsistent therewith.
`
`56.
`
`The ’808 Patent speaks for itself, and HP denies the allegations in Paragraph 56 to
`
`the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the remaining allegations in Paragraph 56, and therefore denies them.
`
`57.
`
`The ’808 Patent speaks for itself, and HP denies the allegations in Paragraph 57 to
`
`the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the allegations in Paragraph 57, and therefore denies them.
`
`10
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`

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`Case 1:23-cv-01237-GBW Document 11 Filed 12/11/23 Page 11 of 83 PageID #: 1845
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`58.
`
`The ’808 Patent speaks for itself, and HP denies the allegations in Paragraph 58 to
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`the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the allegations in Paragraph 58, and therefore denies them.
`
`59.
`
`The ’808 Patent speaks for itself, and HP denies the allegations in Paragraph 59 to
`
`the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the allegations in Paragraph 59, and therefore denies them.
`
`60.
`
`The ’808 Patent speaks for itself, and HP denies the allegations in Paragraph 60 to
`
`the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the allegations in Paragraph 60, and therefore denies them.
`
`61.
`
`The ’808 Patent speaks for itself, and HP denies the allegations in Paragraph 61 to
`
`the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the allegations in Paragraph 61, and therefore denies them.
`
`62.
`
`The ’808 Patent speaks for itself, and HP denies the allegations in Paragraph 62 to
`
`the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the allegations in Paragraph 62, and therefore denies them.
`
`63.
`
`64.
`
`65.
`
`66.
`
`Denied.
`
`Denied.
`
`Denied.
`
`HP admits that it sells laptops with graphics processing units that decode
`
`H.264-compliant video, including the HP Spectre X360 laptop series, which includes an Intel Iris
`
`XE Graphics Processor. HP admits that certain information regarding these products can be
`
`found on the www.hp.com and www.intel.com websites. Otherwise, denied.
`
`67.
`
`Denied.
`
`11
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`

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`Case 1:23-cv-01237-GBW Document 11 Filed 12/11/23 Page 12 of 83 PageID #: 1846
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`68.
`
`HP admits that it publishes reviews of some of its products on the www.hp.com
`
`website. The contents of those reviews speak for themselves, and HP denies the allegations in
`
`Paragraph 68 to the extent inconsistent therewith.
`
`69.
`
`HP admits that it sells desktop computers with graphics processing units that
`
`decode H.264-compliant video, including the HP Pavilion Series of Desktop PC, which includes
`
`either an Intel UHD Graphics 770 or an AMD Radeon Graphics processor. HP admits that
`
`certain information regarding these products can be found on the www.hp.com, www.intel.com,
`
`and www.amd.com websites. Otherwise, denied.
`
`70.
`
`HP admits that it publishes reviews of some of its products on the www.hp.com
`
`website. The contents of those reviews speak for themselves, and HP denies the allegations in
`
`Paragraph 70 to the extent inconsistent therewith.
`
`71.
`
`72.
`
`Denied.
`
`HP admits that it advertises some of its Accused Products on its website for
`
`consumer purchase. Otherwise, denied.
`
`73.
`
`HP admits that it was aware of the ’808 Patent as of the filing of the Complaint in
`
`this action. HP admits that Nokia provided a claim chart in July 2020 that included the ’808
`
`Patent. Otherwise, denied.
`
`74.
`
`75.
`
`Denied.
`
`HP admits that the H.264 Standard can be found in Exhibit 1 to the Complaint.
`
`HP admits that the Complaint attaches a claim chart as Exhibit 12. HP otherwise denies the
`
`allegations of Paragraph 75, including any allegations of infringement.
`
`B.
`
`76.
`
`U.S. Patent No. 8,204,134 (“the ’134 Patent”)
`
`Admitted.
`
`12
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`

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`Case 1:23-cv-01237-GBW Document 11 Filed 12/11/23 Page 13 of 83 PageID #: 1847
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`77.
`
`The ’134 Patent speaks for itself, and HP denies the allegations in Paragraph 77 to
`
`the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the remaining allegations in Paragraph 77, and therefore denies them.
`
`78.
`
`The ’134 Patent speaks for itself, and HP denies the allegations in Paragraph 78 to
`
`the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the remaining allegations in Paragraph 78, and therefore denies them.
`
`79.
`
`The ’134 Patent speaks for itself, and HP denies the allegations in Paragraph 79 to
`
`the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the remaining allegations in Paragraph 79, and therefore denies them.
`
`80.
`
`The ’134 Patent speaks for itself, and HP denies the allegations in Paragraph 80 to
`
`the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the remaining allegations in Paragraph 80, and therefore denies them.
`
`81.
`
`The ’134 Patent speaks for itself, and HP denies the allegations in Paragraph 81 to
`
`the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the remaining allegations in Paragraph 81, and therefore denies them.
`
`82.
`
`83.
`
`84.
`
`Denied.
`
`Denied.
`
`HP admits that it sells laptops with graphics processing units that decode
`
`H.264-compliant video, including the HP Spectre X360 laptop series, which includes an Intel Iris
`
`XE Graphics Processor. HP admits that certain information regarding these products can be
`
`found on the www.hp.com and www.intel.com websites. Otherwise, denied.
`
`85.
`
`Denied.
`
`13
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`Case 1:23-cv-01237-GBW Document 11 Filed 12/11/23 Page 14 of 83 PageID #: 1848
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`86.
`
`HP admits that it publishes reviews of some of its products on the www.hp.com
`
`website. The contents of those reviews speak for themselves, and HP denies the allegations in
`
`Paragraph 86 to the extent inconsistent therewith.
`
`87.
`
`HP admits that it sells desktop computers with graphics processing units that
`
`decode H.264-compliant video, including the HP Pavilion Series of Desktop PC, which includes
`
`either an Intel UHD Graphics 770 or an AMD Radeon Graphics processor. HP admits that
`
`certain information regarding these products can be found on the www.hp.com, www.intel.com,
`
`and www.amd.com websites. Otherwise, denied.
`
`88.
`
`HP admits that it publishes reviews of some of its products on the www.hp.com
`
`website. The contents of those reviews speak for themselves, and HP denies the allegations in
`
`Paragraph 88 to the extent inconsistent therewith.
`
`89.
`
`90.
`
`Denied.
`
`HP admits that it advertises some of its Accused Products on its website for
`
`consumer purchase. Otherwise, denied.
`
`91.
`
`HP admits that it was aware of the ’134 Patent as of the filing of the Complaint in
`
`this action. HP admits that Nokia provided claim charts in July 2020 and May 2021 that included
`
`the ’134 Patent. Otherwise, denied.
`
`92.
`
`93.
`
`Denied.
`
`HP admits that the H.264 Standard can be found in Exhibit 1 to the Complaint.
`
`HP admits that the Complaint attaches a claim chart as Exhibit 13. HP otherwise denies the
`
`allegations of Paragraph 93, including any allegations of infringement.
`
`C.
`
`94.
`
`U.S. Patent No. 7,724,818 (“the ’818 Patent”)
`
`Admitted.
`
`14
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`Case 1:23-cv-01237-GBW Document 11 Filed 12/11/23 Page 15 of 83 PageID #: 1849
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`95.
`
`The ’818 Patent speaks for itself, and HP denies the allegations in Paragraph 95 to
`
`the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the remaining allegations in Paragraph 95, and therefore denies them.
`
`96.
`
`The ’818 Patent speaks for itself, and HP denies the allegations in Paragraph 96 to
`
`the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the remaining allegations in Paragraph 96, and therefore denies them.
`
`97.
`
`The ’818 Patent speaks for itself, and HP denies the allegations in Paragraph 97 to
`
`the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the remaining allegations in Paragraph 97, and therefore denies them.
`
`98.
`
`The ’818 Patent speaks for itself, and HP denies the allegations in Paragraph 98 to
`
`the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the remaining allegations in Paragraph 98, and therefore denies them.
`
`99.
`
`The ’818 Patent speaks for itself, and HP denies the allegations in Paragraph 99 to
`
`the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a belief
`
`as to the truth of the remaining allegations in Paragraph 99, and therefore denies them.
`
`100.
`
`The ’818 Patent speaks for itself, and HP denies the allegations in Paragraph 100
`
`to the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a
`
`belief as to the truth of the remaining allegations in Paragraph 100, and therefore denies them.
`
`101.
`
`The ’818 Patent speaks for itself, and HP denies the allegations in Paragraph 101
`
`to the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a
`
`belief as to the truth of the remaining allegations in Paragraph 101, and therefore denies them.
`
`102. Denied.
`
`103. Denied.
`
`15
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`Case 1:23-cv-01237-GBW Document 11 Filed 12/11/23 Page 16 of 83 PageID #: 1850
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`104. Denied.
`
`105. HP admits that it sells laptops with graphics processing units that decode
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`H.264- and H.265-compliant video, including the HP Spectre X360 laptop series, which includes
`
`an Intel Iris XE Graphics Processor. HP admits that certain information regarding these products
`
`can be found on the www.hp.com and www.intel.com websites. Otherwise, denied.
`
`106. Denied.
`
`107. HP admits that it publishes reviews of some of its products on the www.hp.com
`
`website. The contents of those reviews speak for themselves, and HP denies the allegations in
`
`Paragraph 107 to the extent inconsistent therewith.
`
`108. HP admits that it sells desktop computers with graphics processing units that
`
`decode H.264- and H.265-compliant video, including the HP Pavilion Series of Desktop PC,
`
`which includes either an Intel UHD Graphics 770 or an AMD Radeon Graphics processor. HP
`
`admits that certain information regarding these products can be found on the www.hp.com,
`
`www.intel.com, and www.amd.com websites. Otherwise, denied.
`
`109. HP admits that it publishes reviews of some of its products on the www.hp.com
`
`website. The contents of those reviews speak for themselves, and HP denies the allegations in
`
`Paragraph 109 to the extent inconsistent therewith.
`
`110. Denied.
`
`111. HP admits that it advertises some of its Accused Products on its website for
`
`consumer purchase. Otherwise, denied.
`
`112. HP admits that it was aware of the ’818 Patent as of the filing of the Complaint in
`
`this action. Otherwise, denied.
`
`16
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`Case 1:23-cv-01237-GBW Document 11 Filed 12/11/23 Page 17 of 83 PageID #: 1851
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`113. HP admits that it was aware of the ’818 Patent as of the filing of the Complaint in
`
`this action. HP admits that Nokia provided claim charts in July 2020 and July 2021 that included
`
`the ’818 Patent. Otherwise, denied.
`
`114. Denied.
`
`115. HP admits that the H.264 and H.265 Standards can be found in Exhibits 1 and 2 to
`
`the Complaint. HP admits that the Complaint attaches claim charts as Exhibits 14A and 14B. HP
`
`otherwise denies the allegations of Paragraph 115, including any allegations of infringement.
`
`D.
`
`U.S. Patent No. 10,536,714 (“the ’714 Patent”)
`
`116. Admitted.
`
`117.
`
`The ’714 Patent speaks for itself, and HP denies the allegations in Paragraph 117
`
`to the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a
`
`belief as to the truth of the remaining allegations in Paragraph 117, and therefore denies them.
`
`118.
`
`The ’714 Patent speaks for itself, and HP denies the allegations in Paragraph 118
`
`to the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a
`
`belief as to the truth of the remaining allegations in Paragraph 118, and therefore denies them.
`
`119.
`
`The ’714 Patent speaks for itself, and HP denies the allegations in Paragraph 119
`
`to the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a
`
`belief as to the truth of the remaining allegations in Paragraph 119, and therefore denies them.
`
`120.
`
`The ’714 Patent speaks for itself, and HP denies the allegations in Paragraph 120
`
`to the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a
`
`belief as to the truth of the remaining allegations in Paragraph 120, and therefore denies them.
`
`17
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`Case 1:23-cv-01237-GBW Document 11 Filed 12/11/23 Page 18 of 83 PageID #: 1852
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`121.
`
`The ’714 Patent speaks for itself, and HP denies the allegations in Paragraph 121
`
`to the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a
`
`belief as to the truth of the remaining allegations in Paragraph 121, and therefore denies them.
`
`122.
`
`The ’714 Patent speaks for itself, and HP denies the allegations in Paragraph 122
`
`to the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a
`
`belief as to the truth of the remaining allegations in Paragraph 122, and therefore denies them.
`
`123.
`
`The ’714 Patent speaks for itself, and HP denies the allegations in Paragraph 123
`
`to the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a
`
`belief as to the truth of the remaining allegations in Paragraph 123, and therefore denies them.
`
`124.
`
`The ’714 Patent speaks for itself, and HP denies the allegations in Paragraph 124
`
`to the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a
`
`belief as to the truth of the remaining allegations in Paragraph 124, and therefore denies them.
`
`125.
`
`The ’714 Patent speaks for itself, and HP denies the allegations in Paragraph 125
`
`to the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a
`
`belief as to the truth of the remaining allegations in Paragraph 125, and therefore denies them.
`
`126.
`
`The ’714 Patent speaks for itself, and HP denies the allegations in Paragraph 126
`
`to the extent inconsistent therewith. HP lacks knowledge or information sufficient to form a
`
`belief as to the truth of the remaining allegations in Paragraph 126, and therefore denies them.
`
`127. Denied.
`
`128. Denied.
`
`