throbber
Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 1 of 22
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
`
`
`
`IRONBURG INVENTIONS LTD.
`
`
`Plaintiff,
`
`
`v.
`
`COLLECTIVE MINDS GAMING
`CO. LTD.
`
`
`
`
`
`
`
`
`Civil Action No. 1:16-cv-04110-TWT
`
`Defendant.
`
`
`
`DEFENDANT COLLECTIVE MINDS GAMING CO. LTD.’S
`ANSWER AND AFFIRMATIVE DEFENSES
`
`
`In response to the Complaint for Patent Infringement (“Complaint”) of
`
`Plaintiff Ironburg Inventions Ltd. (“Ironburg”), Defendant Collective Minds
`
`Gaming Co. Ltd. (“Collective Minds”) answers and states as follows:
`
`PARTIES
`
`1.
`
`Collective Minds lacks information sufficient to form a belief as to the truth
`
`of the allegations in Paragraph 1.
`
`2.
`
`Collective Minds lacks information sufficient to form a belief as to the truth
`
`of the allegations in Paragraph 2.
`
`
`
`1
`
`

`

`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 2 of 22
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`3.
`
`Collective Minds admits that it is a company organized and existing under the
`
`laws of Canada and that it has a place of business at 8515 Place Devonshire, Suite
`
`205, Mount Royal, Quebec H4P 2K1, Canada.
`
`JURISDICTION AND VENUE
`
`4.
`
`Collective Minds admits that the Complaint purports to be an action for patent
`
`infringement arising under the patent laws of the United States, 35 U.S.C. §§ 1 et
`
`seq. Collective Minds also admits that this Court has subject matter jurisdiction over
`
`meritorious acts for patent infringement generally pursuant to 28 U.S.C. §§ 1331 and
`
`1338(a). Collective Minds denies, however, that Ironburg’s Complaint sets forth a
`
`valid or meritorious claim for patent infringement.
`
`5.
`
`Collective Minds denies that it has committed or does commit acts allegedly
`
`giving rise to this action, in this District or any District. Collective Minds denies that
`
`venue is proper under 28 U.S.C. 1400(b), but does not dispute venue in this District
`
`for the purposes of this case under current Federal Circuit law.
`
`6.
`
`Collective Minds admits that, on its face, U.S. Patent No. 8,641,525 (“‘525
`
`Patent”) is entitled “Controller for Video Game Console,” was issued on February
`
`4, 2014, and lists Ironburg Inventions Ltd. as an applicant and assignee, but
`
`Collective Minds denies that the ‘525 Patent was issued after a full and fair
`
`examination by the United States Patent and Trademark Office. Collective Minds
`
`
`
`2
`
`

`

`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 3 of 22
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`admits that Exhibit A appears to be a copy of the ‘525 Patent. Collective Minds
`
`denies any remaining allegations of Paragraph 6.
`
`7.
`
`Collective Minds admits that, on its face, U.S. Patent No. 9,089,770 (“‘770
`
`Patent”) is entitled “Controller for Video Game Console,” was issued on July 28,
`
`2015, appears to be a continuation of the ‘525 Patent, and lists Ironburg Inventions
`
`Ltd. as an applicant and assignee, but Collective Minds denies that the ‘770 Patent
`
`was duly and legally issued after a full and fair examination by the United States
`
`Patent and Trademark Office. Collective Minds admits that Exhibit B appears to be
`
`a copy of the ‘770 Patent. Collective Minds denies any remaining allegations of
`
`Paragraph 7.
`
`8.
`
`Collective Minds admits that, on its face, U.S. Patent No. 9,289,688 (“‘688
`
`Patent”) is entitled “Games Controller,” was issued on March 22, 2016, and lists
`
`Ironburg Inventions Ltd. as an applicant and assignee. Collective Minds denies that
`
`the ‘688 Patent was duly and legally issued after a full and fair examination by the
`
`United States Patent and Trademark Office. Collective Minds admits that Exhibit C
`
`appears to be a copy of the ‘688 Patent. Collective Minds denies any remaining
`
`allegations of Paragraph 8.
`
`9.
`
`Collective Minds admits that, on its face, U.S. Patent No. 9,352,229 (“‘229
`
`Patent”), is entitled “Controller for a Games Console,” was issued on May 31, 2016,
`
`
`
`3
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`

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`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 4 of 22
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`and lists Ironburg Inventions Ltd. as an applicant and assignee. Collective Minds
`
`denies that the ‘229 Patent was duly and legally issued after a full and fair
`
`examination by the United States Patent and Trademark Office. Collective Minds
`
`admits that Exhibit D appears to be a copy of the ‘229 Patent. Collective Minds
`
`denies any remaining allegations of Paragraph 9.
`
`10. Collective Minds admits that, on its face, U.S. Patent No. 9,308,450 (“‘450
`
`Patent”), is entitled “Game Controller,” was issued on April 12, 2016, and lists
`
`Ironburg Inventions Ltd. as an applicant and assignee. Collective Minds denies that
`
`the ‘450 Patent was duly and legally issued after a full and fair examination by the
`
`United States Patent and Trademark Office. Collective Minds admits that Exhibit E
`
`appears to be a copy of the ‘450 Patent. Collective Minds denies any remaining
`
`allegations of Paragraph 10.
`
`11. Collective Minds lacks information sufficient to form a belief as to the truth
`
`of the allegations in Paragraph 11 and, therefore, denies the same.
`
`FACTUAL BACKGROUND
`
`12. Collective Minds lacks information sufficient to form a belief as to the truth
`
`of the allegations in Paragraph 12 and, therefore, denies the same.
`
`13. Collective Minds denies that it has made, used, or imported products in this
`
`District or elsewhere in the United States. While Collective Minds admits that
`
`
`
`4
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`

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`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 5 of 22
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`interested buyers, in this District and elsewhere in the United States, may purchase
`
`its Strike Pack product and Trigger Grips product from its website and through third-
`
`party retailers, Collective Minds denies that it has specifically directed marketing or
`
`sales activities to this District. Collective Minds admits that certain Strike Pack
`
`products and Trigger Grips products may be used with a purchaser’s Xbox One
`
`gaming controllers, but, to the extent the Complaint implies as much, denies that it
`
`sells any alleged “modified Xbox One gaming controllers.”1 Collective Minds
`
`denies that any controllers modified with its products incorporate Ironburg’s
`
`patented technologies. Collective Minds denies any remaining allegations of
`
`Paragraph 13.
`
`14. Collective Minds admits that Ironburg sent cease-and-desist communications
`
`to Collective Minds regarding various claims of the ‘525, ‘770, ‘688, ‘229, and ‘450
`
`Patents (collectively, the “Patents-in-Suit”):
`
`• Collective Minds admits that it received correspondence from counsel for
`
`Ironburg on March 4, 2016. Collective Minds admits that this
`
`correspondence alleged that Strike Pack modifications for Xbox One game
`
`controllers related to claim 20 of the ‘525 Patent and claim 1 of the ‘770
`
`
`1 The alleged pictures annexed as Exhibit F to the Complaint are not current
`snapshots of the recited URLs.
`
`
`
`5
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`

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`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 6 of 22
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`Patent. Collective Minds also admits that this letter identified the
`
`application for what would become the ‘450 Patent as well as the Trigger
`
`Grips product in conjunction with pending claim 1 of that application.
`
`• Collective Minds admits it received a cease-and-desist letter from counsel
`
`for Ironburg on March 29, 2016. Collective Minds admits that this letter
`
`alleged that Strike Pack modifications for Xbox One game controllers
`
`related to claim 1 of the ‘688 Patent.
`
`• Collective Minds admits that it received a cease-and-desist letter on April
`
`15, 2016. Collective Minds admits that that this letter alleged that Trigger
`
`Grips modifications for Xbox One game controllers related to claim 1 of
`
`the ‘450 Patent.
`
`• Collective Minds admits that it received a cease-and-desist letter on
`
`October 25, 2016. Collective Minds admits that this letter alleged that
`
`Strike Pack modifications for Xbox One game controllers related to claim
`
`24 of the ‘229 Patent.
`
`Further answer, to the extent the Complaint implies such, Collective Minds denies
`
`that any of its products infringe any valid claim of the Patents-in-Suit. Collective
`
`Minds denies any remaining allegations in Paragraph 14.
`
`
`
`6
`
`

`

`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 7 of 22
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`15. Collective Minds denies that any of its products infringe any valid claim of
`
`the Patents-in-Suit. Collective Minds denies that it markets or sells any game
`
`controllers, modified or otherwise, in the United States. Collective Minds admits that
`
`it sells some of its products through third-party retailers such as Amazon.com, Best
`
`Buy, EBGames, and GameStop, but it denies that any products sold through such
`
`retailers infringe any valid claim of the Patents-in-Suit. Collective Minds denies any
`
`remaining allegations of Paragraph 15.
`
`COUNT I
`(Direct and Induced Infringement of U.S. Patent No. 8,641,525)
`
`16. Collective Minds incorporates its responses to Paragraphs 1 through 15 by
`
`reference.
`
`17. Collective Minds does not dispute the Complaint’s use of the phrase “Strike
`
`Pack Modified Controller” to mean an Xbox One gaming controller modified with
`
`Collective Minds’ Strike Pack module. Collective Minds denies any remaining
`
`allegations of Paragraph 17.
`
`18. Collective Minds admits that the ‘525 Patent has only two independent claims
`
`(claims 1 and 20) and that each and every claim of the ‘525 Patent is directed to a
`
`gaming controller. Collective Minds admits that the remaining claims of the ‘525
`
`Patent depend from claim 1 and include additional limitations. Collective Minds
`
`denies the paraphrasing of the claims set forth in the Complaint and instead states
`7
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`

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`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 8 of 22
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`that the proper scope of these claims will be determined through the claim
`
`construction process. Collective Minds denies that the Strike Pack Modified
`
`Controller include each of the elements of claims 1, 12, 15, 20, or any other claim
`
`of the ‘525 Patent, either literally or under a theory of the doctrine of equivalents.
`
`Collective Minds further denies the accuracy of any claim construction, express or
`
`implied, in Paragraph 18. To the extent the Complaint alleges such, Collective Minds
`
`denies that it makes, uses, sells, offers to sell, or imports any “Modified Controllers”
`
`in the United States. Collective Minds denies any remaining allegations of Paragraph
`
`18.
`
`19. Denied.
`
`20. Denied.
`
`21. Denied.
`
`22. Denied.
`
`23. Denied.
`
`COUNT II
`(Direct and Induced Infringement of U.S. Patent No. 9,089,770)
`
`24. Collective Minds incorporates its responses to Paragraphs 1 through 23 by
`
`reference.
`
`25. Collective Minds does not dispute the Complaint’s use of the phrase “Strike
`
`Pack Modified Controller” to mean an Xbox One gaming controller modified with
`8
`
`
`
`

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`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 9 of 22
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`Collective Minds’ Strike Pack module. Collective Minds otherwise denies any
`
`remaining allegations of Paragraph 25.
`
`26. Collective Minds admits that the ‘770 Patent has only one independent claim
`
`(claim 1) and that each and every claim of the ‘770 Patent is directed to a gaming
`
`controller. Collective Minds admits that claim 13 depends from claim 1 of the ‘770
`
`Patent (and notes that claim 13 also depends from claim 12). Collective Minds denies
`
`the paraphrasing of the claims set forth in the Complaint and instead states that the
`
`proper scope of these claims will be determined through the claim construction
`
`process. Collective Minds denies that any of its products or the Strike Pack Modified
`
`Controller include each element of claims 1 and 13, or any other claim of the ‘770
`
`Patent, either literally or under a theory of the doctrine of equivalents. Collective
`
`Minds further denies the accuracy of any claim construction, express or implied, in
`
`Paragraph 26. To the extent the Complaint alleges such, Collective Minds denies
`
`that it makes, uses, sells, offers to sell, or imports any “Modified Controllers” in the
`
`United States. Collective Minds denies any remaining allegations of Paragraph 26.
`
`27. Denied.
`
`28. Denied.
`
`29. Denied.
`
`30. Denied.
`
`
`
`9
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`

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`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 10 of 22
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`31. Denied.
`
`COUNT III
`(Direct and Induced Infringement of U.S. Patent No. 9,289,688)
`
`32. Collective Minds incorporates its responses to Paragraphs 1 through 31 by
`
`reference.
`
`33. Collective Minds does not dispute the Complaint’s use of the phrase “Strike
`
`Pack Modified Controller” to mean an Xbox One gaming controller modified with
`
`Collective Minds’ Strike Pack module. Collective Minds otherwise denies any
`
`remaining allegations of Paragraph 33.
`
`34. Collective Minds admits that the ‘688 Patent has only two independent claims
`
`(claims 1 and 30) and that and that each and every claim of the ‘688 Patent is directed
`
`to a gaming controller. Collective Minds denies the paraphrasing of the claims set
`
`forth in the Complaint and instead states that the proper scope of these claims will
`
`be determined through the claim construction process. Collective Minds denies that
`
`any of its products or the Strike Pack Modified Controller include each element of
`
`claim 1, or any other claim of the ‘688 Patent, either literally or under a theory of
`
`the doctrine of equivalents. Collective Minds further denies the accuracy of any
`
`claim construction, express or implied, in Paragraph 34. To the extent the Complaint
`
`alleges such, Collective Minds denies that it makes, uses, sells, offers to sell, or
`
`
`
`10
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`

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`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 11 of 22
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`imports any “Modified Controllers” in the United States. Collective Minds denies
`
`any remaining allegations of Paragraph 34.
`
`35. Denied.
`
`36. Denied.
`
`37. Denied.
`
`38. Denied.
`
`39. Denied.
`
`COUNT IV
`(Direct and Induced Infringement of U.S. Patent No. 9,352,229)
`
`40. Collective Minds incorporates its responses to Paragraphs 1 through 39 by
`
`reference.
`
`41. Collective Minds does not dispute the Complaint’s use of the phrase “Strike
`
`Pack Modified Controller” to mean an Xbox One gaming controller modified with
`
`Collective Minds’ Strike Pack module. Collective Minds otherwise denies any
`
`remaining allegations of Paragraph 41.
`
`42. Collective Minds admits that the ‘229 Patent has only two independent claims
`
`(claims 1 and 24) and that each and every claim of the ‘229 Patent is directed to a
`
`gaming controller. Collective Minds denies the paraphrasing of the claims set forth
`
`in the Complaint and instead states that the proper scope of these claims will be
`
`determined through the claim construction process. Collective Minds denies that any
`11
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`

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`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 12 of 22
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`of its products or the Strike Pack Modified Controller includes each element of claim
`
`1 or 24, or any other claim of the ‘229 Patent, either literally or under a theory of the
`
`doctrine of equivalents. Collective Minds further denies the accuracy of any claim
`
`construction, express or implied, in Paragraph 42. To the extent the Complaint
`
`alleges such, Collective Minds denies that it makes, uses, sells, offers to sell, or
`
`imports any “Modified Controllers” in the United States. Collective Minds denies
`
`any remaining allegations of Paragraph 42.
`
`43. Denied.
`
`44. Denied.
`
`45. Denied.
`
`46. Denied.
`
`47. Denied.
`
`COUNT V
`(Direct and Induced Infringement of U.S. Patent No. 9,308,450)2
`
`48. Collective Minds incorporates its responses to Paragraphs 1 through 47 by
`
`reference.
`
`
`2 The reference to the ‘688 Patent in the heading appears to be a typographical error.
`Collective Minds assumes that Count V is directed to U.S. Patent No. 9,308,450.
`
`
`
`12
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`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 13 of 22
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`49. Collective Minds does not dispute the Complaint’s use of the phrase “Trigger
`
`Grips Modified Controller” to mean an Xbox One gaming controller modified with
`
`Collective Minds’ Trigger Grips kit. Collective Minds otherwise denies any
`
`remaining allegations of Paragraph 49.
`
`50. Collective Minds admits that the ‘450 Patent has only one independent claim
`
`(claim 1) and that each and every claim of the ‘450 Patent is directed to a gaming
`
`controller. Collective Minds denies the paraphrasing of the claims set forth in the
`
`Complaint and instead states that the proper scope of these claims will be determined
`
`through the claim construction process. Collective Minds denies that any of its
`
`products or the Trigger Grips Modified Controller include each element of claim 1,
`
`or any other claim of the ‘450 Patent, either literally or under a theory of the doctrine
`
`of equivalents. Collective Minds further denies the accuracy of any claim
`
`construction, express or implied, in Paragraph 50. To the extent the Complaint
`
`alleges such, Collective Minds denies that it makes, uses, sells, offers to sell, or
`
`imports any “Modified Controllers” in the United States. Collective Minds denies
`
`any remaining allegations of Paragraph 50.
`
`51. Denied.
`
`52. Denied.
`
`53. Denied.
`
`
`
`13
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`

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`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 14 of 22
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`54. Denied.
`
`55. Denied.
`
`INCREASED DAMAGES UNDER 35 U.S.C. § 284
`
`56. Collective Minds incorporates its responses to Paragraphs 1 through 55 by
`
`reference.
`
`57. Denied.
`
`58. Denied.
`
`59. Denied.
`
`60. Denied.
`
`61. To the extent any allegation contained in the Complaint is not specifically
`
`admitted in Collective Minds’ Answer, it is hereby denied. Collective Minds also
`
`denies any allegations that may be implied by or inferred from the headings of
`
`Ironburg’s Complaint.
`
`REQUEST FOR RELIEF
`
`
`
`Collective Minds denies that Ironburg is entitled to any relief in connection
`
`with the allegations set forth in its Complaint, including, but not limited to, the
`
`allegations and requests for judgment set forth in Paragraphs (A) through (F) of
`
`Ironburg’s Request for Relief.
`
`
`
`
`
`14
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`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 15 of 22
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`DEFENSES
`
`Without admitting or acknowledging that Collective Minds bears the burden
`
`of proof as to any of the following defenses, based upon information and belief,
`
`Collective Minds asserts the following defenses:
`
`FIRST DEFENSE
`(Non-infringement of the Patents-in-Suit)
`
`
`
`Collective Minds has not infringed, either literally or under the doctrine of
`
`equivalents, either directly or indirectly, any valid and enforceable claims of the ‘525
`
`Patent, the ‘770 Patent, the ‘688 Patent, the ‘229 Patent, and/or the ‘450 Patent
`
`(collectively, the “Patents-in-Suit”) referenced in the Complaint.
`
`1.
`
`Collective Minds has not infringed, either literally or under the doctrine
`
`of equivalents, either directly or indirectly, any valid and enforceable claim of the
`
`‘525 Patent asserted in the Complaint.
`
`2.
`
`Collective Minds has not infringed, either literally or under the doctrine
`
`of equivalents, either directly or indirectly, any valid and enforceable claim of the
`
`‘770 Patent asserted in the Complaint.
`
`3.
`
`Collective Minds has not infringed, either literally or under the doctrine
`
`of equivalents, either directly or indirectly, any valid and enforceable claim of the
`
`’688 Patent asserted in the Complaint.
`
`
`
`15
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`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 16 of 22
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`4.
`
`Collective Minds has not infringed, either literally or under the doctrine
`
`of equivalents, either directly or indirectly, any valid and enforceable claim of the
`
`’229 Patent asserted in the Complaint.
`
`5.
`
`Collective Minds has not infringed, either literally or under the doctrine
`
`of equivalents, either directly or indirectly, any valid and enforceable claim of the
`
`’450 Patent asserted in the Complaint
`
`SECOND DEFENSE
`(Invalidity of the Patents-in-Suit)
`
`1.
`
`One or more claims of the ’525 Patent asserted in the Complaint are
`
`invalid because they fail to satisfy the conditions of patentability set forth in Title 35
`
`of the United States Code, including, but not limited to, 35 U.S.C. §§ 101, 102, 103,
`
`and/or 112.
`
`2.
`
`One or more claims of the ’770 Patent asserted in the Complaint are
`
`invalid because they fail to satisfy the conditions of patentability set forth in Title 35
`
`of the United States Code, including, but not limited to, 35 U.S.C. §§ 101, 102, 103,
`
`and/or 112.
`
`3.
`
`One or more claims of the ’688 Patent asserted in the Complaint are
`
`invalid because they fail to satisfy the conditions of patentability set forth in Title 35
`
`
`
`16
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`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 17 of 22
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`of the United States Code, including, but not limited to, 35 U.S.C. §§ 101, 102, 103,
`
`and/or 112.
`
`4.
`
`One or more claims of the ’229 Patent asserted in the Complaint are
`
`invalid because they fail to satisfy the conditions of patentability set forth in Title 35
`
`of the United States Code, including, but not limited to, 35 U.S.C. §§ 101, 102, 103,
`
`and/or 112.
`
`5.
`
`One or more claims of the ’450 Patent asserted in the Complaint are
`
`invalid because they fail to satisfy the conditions of patentability set forth in Title 35
`
`of the United States Code, including, but not limited to, 35 U.S.C. §§ 101, 102, 103,
`
`and/or 112.
`
`THIRD DEFENSE
`(Limitation on Damages)
`
`
`
`To the extent that Ironburg seeks damages for allegedly infringing activity
`
`past the time set forth in 35 U.S.C. § 286, such claims are barred.
`
`FOURTH DEFENSE
`(Failure to Mark)
`
`
`
`Ironburg’s claims for damages for purported patent infringement are limited
`
`at least in part by 35 U.S.C. § 287.
`
`
`
`
`
`
`
`17
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`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 18 of 22
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`FIFTH DEFENSE
`(Cost Recovery)
`
`Ironburg is barred at least in part by 35 U.S.C. § 288 from recovering costs
`
`associated with its action.
`
`RESERVATION OF ADDITIONAL DEFENSES
`
`
`
`Collective Minds expressly reserves the right to raise and allege any and all
`
`additional defenses and counterclaims as they become known through further
`
`investigations and discovery.
`
`JURY DEMAND
`
`
`
`Collective Minds respectfully demands a jury trial of all issues triable to a
`
`jury.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Collective Minds prays for judgment that:
`
`A. Collective Minds has not infringed and is not infringing any of the
`
`claims of the Patents-in-Suit;
`
`B.
`
`C.
`
`The Patents-in-Suit are invalid;
`
`Finds judgment in favor of Collective Minds and against Ironburg on
`
`all claims in Ironburg’s Complaint;
`
`D. Dismisses Ironburg’s Complaint with prejudice, with Ironburg taking
`
`nothing by its Complaint;
`
`
`
`18
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`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 19 of 22
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`E. Awards Collective Minds its fees and costs, including attorneys’ fees
`
`incurred herein; and
`
`F.
`
`Grants Collective Minds such other and further relief as the Court
`
`may deem just and proper.
`
`Dated: April 25, 2017
`
`
`
`
`
`Respectfully submitted,
`
`HILL, KERTSCHER & WHARTON, LLP
`
`/s/ Steven G. Hill
`
`
`Steven G. Hill, GA Bar No. 354658
`Martha L. Decker, GA Bar No. 420867
`3350 Riverwood Parkway, Suite 800
`Atlanta, Georgia 30339
`Telephone: (770) 953-0995
`Facsimile: (770) 953-1358
`Email:
`sgh@hkw-law.com
`
`
`md@hkw-law.com
`
`ERISE IP, P.A.
`Eric A. Buresh, admitted pro hac vice
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`Telephone: (913) 777-5600
`Facsimile: (913) 777-5601
`Email:
`eric.buresh@eriseip.com
`
`
`ERISE IP, P.A.
`Paul R. Hart, admitted pro hac vice
`Michelle A. Callaghan, admitted pro hac vic
`5600 Greenwood Plaza Blvd., Suite 200
`Greenwood Village, CO 80111
`Telephone: (913) 777-5600
`Facsimile: (913) 777-5601
`Email: paul.hart@eriseip.com
`19
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`

`

`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 20 of 22
`
` michelle.callaghan@eriseip.com
`
`
`
`Attorneys for Defendant Collective
`Minds Gaming Co. Ltd
`
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`20
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`

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`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 21 of 22
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`CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1D
`
`Pursuant to LR 7.1(D), the undersigned counsel certifies that this document
`
`
`
`
`has been prepared using Times New Roman 14-point font, as permitted under LR
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`
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`5.1(C).
`
`Dated: April 25, 2017
`
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`Respectfully submitted,
`
`/s/ Steven G. Hill
`Steven G. Hill
`GA Bar No. 354658
`
`Attorney for Defendant
`Collective Minds Gaming Co. Ltd.
`
`

`

`Case 1:16-cv-04110-TWT Document 22 Filed 04/25/17 Page 22 of 22
`
`CERTIFICATE OF SERVICE
`
`The undersigned counsel hereby certifies that on April 25, 2017, a true and
`
`correct copy of the DEFENDANT COLLECTIVE MINDS GAMING CO.
`LTD’S ANSWER AND AFFIRMATIVE DEFENSES was filed with the Clerk of
`Court using the CM/ECF system, which will automatically send email notification
`of such filing to the following attorneys of record:
`
`
`Cynthia R. Parks
`Parks IP Law LLC
`75 Ponce de Leon Avenue, NE, Suite 102
`Atlanta, GA 30308
`T: 678.365.4444
`F: 678.365.4450
`cparks@parksiplaw.com
`
`Robert D. Becker
`Manatt, Phelps & Phillips, LLP
`1841 Page Mill Road, Suite 200
`Palo Alto, CA 94304
`T: 650.812.1300
`F: 650.213.0260
`rbecker@manatt.com
`
`Respectfully submitted,
`
`/s/ Steven G. Hill
`Steven G. Hill
`Georgia Bar No. 354658
`
`
`
`
`
`Attorney for Defendant
`Collective Minds Gaming Co. Ltd.
`
`
`Dated: April 25, 2017
`
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`

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