Case 1:18-cv-10355-WGY Document 18 Filed 05/18/18 Page 1 of 24
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MASSACHUSETTS
`
`
`
`Case No. 1:18-cv-10355
`
`JURY TRIAL DEMANDED
`
`REALTIME ADAPTIVE STREAMING LLC,
`
` Plaintiff,
`
`
`v.
`
`
`ADOBE SYSTEMS INC.,
`
` Defendant.
`
`
`
`
`ANSWER AND AFFIRMATIVE DEFENSES BY
`DEFENDANT ADOBE SYSTEMS INCORPORATED
`
`
`
`Pursuant to Rule 8 of the Federal Rules of Civil Procedure and Order 16, Defendant
`
`Adobe Systems Incorporated (“Adobe”), hereby responds to the Complaint for Patent
`
`Infringement of Plaintiff Realtime Adaptive Streaming LLC (“Realtime”), on personal
`
`knowledge as to its own activities and on information and belief as to the activities of others as
`
`follows:
`
`Adobe denies each and every allegation contained in the Complaint that is not
`
`expressly admitted below. Any factual allegation admitted below is admitted only as to the
`
`specific admitted facts, not as to any purported conclusions, characterizations, implications, or
`
`speculations that arguably follow from the admitted facts. Adobe denies that Realtime is entitled
`
`to the relief requested or any other relief.
`
`PARTIES
`
`1.
`
`Adobe is without information or knowledge sufficient to form a belief as to
`
`the truth or falsity of the allegations of paragraph 1, and therefore denies them.
`
`2.
`
`Adobe admits that it is a Delaware corporation with its corporate headquarters
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`

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`Case 1:18-cv-10355-WGY Document 18 Filed 05/18/18 Page 2 of 24
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`located at 345 Park Avenue, San Jose, California 95110.
`
`3.
`
`Adobe admits that it has regular and established places of business in this
`
`District and that it offers its products and/or services, including at least some of those accused
`
`herein of infringement, to customers and potential customers located in this District. Adobe
`
`denies that it has committed any acts of infringement in this District or elsewhere. Adobe denies
`
`that venue is convenient in this District. To the extent there are any remaining allegations in
`
`paragraph 3, Adobe denies them.
`
`4.
`
`5.
`
`Admitted.
`
`JURISDICTION AND VENUE
`
`Adobe admits that the Complaint purports to allege a claim for patent
`
`infringement under the patent laws of the United States, Title 35 of the United States Code, and
`
`that this Court has jurisdiction over patent actions pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`
`6.
`
`Adobe denies that it has committed acts of infringement in this District or
`
`elsewhere. Adobe admits that it conducts business in this District. For purposes of this action only,
`
`Adobe admits it is subject to personal jurisdiction in this District. Adobe otherwise denies the
`
`allegations of paragraph 6.
`
`7.
`
`For the purposes of this action only, Adobe does not contest that venue in this
`
`District is proper under 28 U.S.C. § 1400(b), but Adobe denies that venue is convenient for this
`
`case. Adobe admits it has lawfully transacted business in this District, but denies that it has
`
`committed acts of direct or indirect infringement in this District or elsewhere.
`
`THE PATENTS-IN-SUIT
`
`8.
`
`Adobe admits that this action arises under 35 U.S.C. § 271 for alleged
`
`infringement of United States Patents 7,386,046 (the “’046 Patent”), 8,634,462 (the “’462
`
`

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`Case 1:18-cv-10355-WGY Document 18 Filed 05/18/18 Page 3 of 24
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`Patent”), 8,929,442 (the “’442 Patent”), 8,934,535 (the “’535 Patent”), 9,578,298 (the “’298
`
`Patent”), 9,762,907 (the “’907 Patent”), and 9,769,477 (the “’477 Patent”) (collectively, the
`
`“Patents-In-Suit”). Adobe is without information or knowledge sufficient to form a belief as to
`
`whether Realtime owns the Patents-In-Suit. Adobe denies any remaining allegations in
`
`paragraph 8.
`
`9.
`
`Adobe admits that the ʼ046 Patent on its face is titled “Bandwidth Sensitive
`
`Data Compression and Decompression” and that it appears to have issued on June 10, 2008.
`
`Adobe denies that the ʼ046 Patent was “duly and properly issued.” Adobe admits that a copy
`
`of what appears to be the ʼ046 Patent was attached to the Complaint as Exhibit A. Adobe is
`
`without information or knowledge sufficient to form a belief as to the truth or falsity of the
`
`remaining allegations of paragraph 9, and therefore denies them.
`
`10.
`
`Adobe admits that the ʼ462 Patent on its face is titled “Quantization for Hybrid
`
`Video Coding” and that it appears to have issued on January 21, 2014. Adobe denies that the
`
`ʼ432 Patent was “duly and properly issued.” Adobe admits that a copy of what appears to be the
`
`ʼ462 Patent was attached to the Complaint as Exhibit B. Adobe is without information or
`
`knowledge sufficient to form a belief as to the truth or falsity of the remaining allegations of
`
`paragraph 10, and therefore denies them.
`
`11.
`
`Adobe admits that the ʼ442 Patent on its face is titled “System and Methods for
`
`Video and Audio Data Distribution” and that it appears to have issued on January 6, 2015. Adobe
`
`denies that the ʼ442 Patent was “duly and legally issued.” Adobe admits that a copy of what
`
`appears to be the ʼ442 Patent was attached to the Complaint as Exhibit C. Adobe is without
`
`information or knowledge sufficient to form a belief as to the truth or falsity of the remaining
`
`allegations of paragraph 11, and therefore denies them.
`
`

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`12.
`
`Adobe admits that the ʼ535 Patent on its face is titled “Systems and Methods for
`
`Video and Audio Data Storage and Distribution” and that it appears to have issued on January
`
`13, 2015. Adobe denies that the ʼ535 Patent was “duly and properly issued.” Adobe admits
`
`that a copy of what appears to be the ʼ535 Patent was attached to the Complaint as Exhibit C.
`
`Adobe is without information or knowledge sufficient to form a belief as to the truth or falsity of
`
`the remaining allegations of paragraph 12, and therefore denies them.
`
`13.
`
`Adobe admits that the ʼ298 Patent on its face is entitled “Method for Decoding
`
`2D-Compatible Stereoscopic Video Flows” and that it appears to have issued on February 21,
`
`2017. Adobe denies that the ʼ298 Patent was “duly and properly issued.” Adobe admits that a
`
`copy of what appears to be the ʼ298 Patent was attached to the Complaint as Exhibit E. Adobe
`
`is without information or knowledge sufficient to form a belief as to the truth or falsity of the
`
`remaining allegations of paragraph 13, and therefore denies them.
`
`14.
`
`Adobe admits that the ʼ907 on its face is titled “System and Methods for Video
`
`and Audio Data Distribution” and that it appears to have issued on September 12, 2017. Adobe
`
`denies that the ʼ907 Patent was “duly and properly issued.” Adobe admits that a copy of what
`
`appears to be the ʼ907 Patent was attached to the Complaint as Exhibit F. Adobe is without
`
`information or knowledge sufficient to form a belief as to the truth or falsity of the remaining
`
`allegations of paragraph 14, and therefore denies them.
`
`15.
`
`Adobe admits that the ʼ477 Patent on its face is titled “Video Data Compression
`
`Systems” and that it appears to have issued on September 19, 2017. Adobe denies that the ʼ477
`
`Patent was “duly and properly issued.” Adobe admits that a copy of what appears to be the ʼ477
`
`Patent was attached to the Complaint as Exhibit G. Adobe is without information or knowledge
`
`sufficient to form a belief as to the truth or falsity of the remaining allegations of paragraph 15,
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`

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`Case 1:18-cv-10355-WGY Document 18 Filed 05/18/18 Page 5 of 24
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`and therefore denies them.
`
`COUNT I
`
`[ALLEGED] INFRINGEMENT OF U.S. PATENT NO. 7,386,046
`
`16.
`
`Adobe incorporates by reference all the foregoing responses as if fully set forth
`
`herein.
`
`17.
`
`Adobe admits that it has at times offered certain versions of Adobe Media
`
`Encoder, Media Encoder Creative Cloud, Media Encoder Creative Suite, Premiere Pro, Premiere
`
`Pro CC, Premiere Pro CS, Flash, Flash Player, Flash Media Server, Flash Media Encoding
`
`Server, After Effects, After Effects CC, After Effects CS, and/or HTTP Dynamic Streaming
`
`(HDS). Adobe denies that any of its products infringe the ʼ046 Patent. Adobe otherwise denies
`
`paragraph 17.
`
`18.
`
`19.
`
`Denied.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.264. Adobe denies that its products infringe the ʼ046 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately described the Adobe accused products.
`
`Adobe otherwise denies paragraph 19.
`
`20.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain types of compression. Adobe denies that its products infringe the ʼ046 Patent. Adobe
`
`denies that paragraph 20 accurately describes the Adobe accused products. Adobe otherwise
`
`denies paragraph 20.
`
`21.
`
`Adobe admits that certain versions of certain of the accused products support
`
`

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`Case 1:18-cv-10355-WGY Document 18 Filed 05/18/18 Page 6 of 24
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`certain aspects of H.264. Adobe denies that its products infringe the ‘046 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately described the Adobe accused products.
`
`Adobe otherwise denies paragraph 21.
`
`22.
`
`Realtime appears to have quoted from various websites. It is unclear why
`
`Realtime quoted these websites; to the extent it contends these websites support its claims of
`
`infringement, Adobe denies such allegations and denies that Realtime has accurately described
`
`the Adobe accused products. Adobe otherwise denies paragraph 22.
`
`23.
`
`Adobe admits that certain versions of certain of the accused products practice
`
`certain aspects of H.264. Adobe denies that its products infringe the ʼ046 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately describe the Adobe accused products. Adobe
`
`otherwise denies paragraph 23.
`
`24.
`
`Adobe admits that certain versions of certain of the accused products practice
`
`certain aspects of H.264. Adobe denies that its products infringe the ‘046 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately describe the Adobe accused products. Adobe
`
`otherwise denies paragraph 24.
`
`25.
`
`26.
`
`Denied.
`
`Denied.
`
`

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`27.
`
`28.
`
`29.
`
`Denied.
`
`Denied.
`
`Adobe admits that it has had knowledge of the ʼ046 Patent since sometime after
`
`the filing of Realtime’s complaint. Adobe denies any remaining allegations of paragraph 29.
`
`30.
`
`Adobe admits that certain versions of certain of the accused products practice
`
`certain aspects of H.264. Adobe denies that any of its accused products infringe the ʼ046 Patent.
`
`Adobe denies the remaining allegations of paragraph 30.
`
`31.
`
`32.
`
`33.
`
`Denied.
`
`Denied.
`
`Denied.
`
`COUNT II
`
`[ALLEGED] INFRINGEMENT OF U.S. PATENT NO. 8,634,462
`
`34.
`
`Adobe re-incorporates by reference all previous paragraphs as if fully set forth
`
`herein.
`
`35.
`
`Adobe admits that it has at times offered certain versions of Adobe Media
`
`Encoder, Media Encoder Creative Cloud, Media Encoder Creative Suite, Premiere Pro, Premiere
`
`Pro CC, Premiere Pro CS, After Effects, After Effects CC, and/or After Effects CS. Adobe
`
`denies that any of its products infringe the ʼ462 Patent. Adobe otherwise denies paragraph 35.
`
`36.
`
`37.
`
`Denied.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.265 or “High Efficiency Video Coding.” Adobe denies that its products
`
`infringe the ʼ462 Patent. Realtime appears to have quoted from various websites. It is unclear
`
`why Realtime quoted these websites; to the extent it contends these websites support its claims
`
`

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`Case 1:18-cv-10355-WGY Document 18 Filed 05/18/18 Page 8 of 24
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`of infringement, Adobe denies such allegations and denies that Realtime has accurately describe
`
`the Adobe accused products. Adobe otherwise denies paragraph 37.
`
`38.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.265 or “High Efficiency Video Coding.” Adobe denies that its products
`
`infringe the ʼ462 Patent. Adobe otherwise denies paragraph 38.
`
`39.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.265 or “High Efficiency Video Coding.” Adobe denies that its products
`
`infringe the ʼ462 Patent. Adobe otherwise denies paragraph 39.
`
`40.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.265 or “High Efficiency Video Coding.” Adobe denies that its products
`
`infringe the ʼ462 Patent. Adobe otherwise denies paragraph 40.
`
`41.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.265 or “High Efficiency Video Coding.” Adobe denies that its products
`
`infringe the ʼ462 Patent. Adobe otherwise denies paragraph 41.
`
`42.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.265 or “High Efficiency Video Coding.” Adobe denies that its products
`
`infringe the ʼ462 Patent. Adobe otherwise denies paragraph 42.
`
`43.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.265 or “High Efficiency Video Coding.” Adobe denies that its products
`
`infringe the ʼ462 Patent. Adobe otherwise denies paragraph 43.
`
`44.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.265 or “High Efficiency Video Coding.” Adobe denies that its products
`
`infringe the ʼ462 Patent. Adobe otherwise denies paragraph 44.
`
`

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`45.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.265 or “High Efficiency Video Coding.” Adobe denies that its products
`
`infringe the ʼ462 Patent. Adobe otherwise denies paragraph 45.
`
`46.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.265 or “High Efficiency Video Coding.” Adobe denies that its products
`
`infringe the ʼ462 Patent. Adobe otherwise denies paragraph 46.
`
`47.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.265 or “High Efficiency Video Coding.” Adobe denies that its products
`
`infringe the ʼ462 Patent. Adobe otherwise denies paragraph 47.
`
`48.
`
`49.
`
`50.
`
`51.
`
`52.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Adobe admits that it has had knowledge of the ʼ462 Patent since sometime after
`
`the filing of Realtime’s complaint. Adobe denies the remainder of paragraph 52.
`
`53.
`
`Adobe admits that certain versions of certain of the accused products practice
`
`certain aspects of H.265. Adobe denies that any of its accused products infringe the ʼ046 Patent.
`
`Adobe denies the remaining allegations of paragraph 53.
`
`54.
`
`55.
`
`56.
`
`Denied.
`
`Denied.
`
`Denied.
`
`

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`Case 1:18-cv-10355-WGY Document 18 Filed 05/18/18 Page 10 of 24
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`COUNT III
`
`[ALLEGED] INFRINGEMENT OF U.S. PATENT NO.8,929,442
`
`57.
`
`Adobe re-incorporates by reference all previous paragraphs as if fully set forth
`
`herein.
`
`58.
`
`Adobe admits that it has at times offered certain versions of Adobe Premiere
`
`Pro, Premiere Pro CC, Premiere Pro CS, Flash, Flash Player, Flash Media Server, After Effects,
`
`After Effects CC, After Effects CS, and/or Adobe HTTP Dynamic Streaming (HDS). Adobe
`
`denies that any of its products infringe the ʼ442 Patent. Adobe otherwise denies paragraph 58.
`
`59.
`
`60.
`
`Denied.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.264. Adobe denies that its products infringe the ʼ442 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately described the Adobe accused products.
`
`Adobe otherwise denies paragraph 60.
`
`61.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain types of compression. Adobe denies that its products infringe ʼ442 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately described the Adobe accused products.
`
`Adobe otherwise denies paragraph 61.
`
`62.
`
`Adobe admits that certain versions of certain of the accused instrumentalities
`
`support certain types of compression. Adobe denies that its products infringe ʼ442 Patent.
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`Case 1:18-cv-10355-WGY Document 18 Filed 05/18/18 Page 11 of 24
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`Realtime appears to have quoted from various websites. It is unclear why Realtime quoted these
`
`websites; to the extent it contends these websites support its claims of infringement, Adobe
`
`denies such allegations and denies that Realtime has accurately described the Adobe accused
`
`products. Adobe otherwise denies paragraph 62.
`
`63.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain types of compression. Adobe denies that its products infringe ʼ442 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately described the Adobe accused products.
`
`Adobe otherwise denies paragraph 63.
`
`64.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain types of compression. Adobe denies that its products infringe ʼ442 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately described the Adobe accused products.
`
`Adobe otherwise denies paragraph 64.
`
`65.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain types of compression. Adobe denies that its products infringe ʼ442 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately described the Adobe accused products.
`
`Adobe otherwise denies paragraph 65.
`
`66.
`
`Denied.
`
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`Case 1:18-cv-10355-WGY Document 18 Filed 05/18/18 Page 12 of 24
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`67.
`
`68.
`
`69.
`
`70.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Adobe admits that it has had knowledge of the ʼ442 Patent since sometime after
`
`the filing of Realtime’s complaint. Adobe denies any remaining allegations in paragraph 70.
`
`71.
`
` Adobe admits that certain versions of certain of the accused products practice
`
`certain aspects of H.264. Adobe denies that any of its accused products infringe the ʼ442 Patent.
`
`Adobe denies the remaining allegations of paragraph 71.
`
`72.
`
`73.
`
`74.
`
`Denied.
`
`Denied.
`
`Denied.
`
`COUNT IV
`
`[ALLEGED] INFRINGEMENT OF U.S. PATENT NO. 9,934,535
`
`75.
`
`Adobe re-incorporates by reference all previous paragraphs as if fully set forth
`
`herein.
`
`76.
`
`Adobe admits that it has at times offered certain versions of Adobe Media
`
`Encoder, Media Encoder Creative Cloud, Media Encoder Creative Suite, Premiere Pro, Premiere
`
`Pro CC, Premiere Pro CS, Flash, Flash Player, Flash Media Server, Flash Media Encoding
`
`Server, After Effects, After Effects CC, After Effects CS, and/or HTTP Dynamic Streaming
`
`(HDS). Adobe denies that any of its products infringe the ʼ535 Patent. Adobe otherwise denies
`
`paragraph 76.
`
`77.
`
`78.
`
`Denied.
`
`Adobe admits that certain versions of certain of the accused products support
`
`

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`Case 1:18-cv-10355-WGY Document 18 Filed 05/18/18 Page 13 of 24
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`certain aspects of H.264. Adobe denies that its products infringe the ʼ535 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately described the Adobe accused products.
`
`Adobe otherwise denies paragraph 78.
`
`79.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.264. Adobe denies that its products infringe the ʼ535 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately described the Adobe accused products.
`
`Adobe otherwise denies paragraph 19.
`
`80.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.264. Adobe denies that its products infringe the ʼ535 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately described the Adobe accused products.
`
`Adobe otherwise denies paragraph 80.
`
`81.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.264. Adobe denies that its products infringe the ʼ535 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately described the Adobe accused products.
`
`Adobe otherwise denies paragraph 81.
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`Case 1:18-cv-10355-WGY Document 18 Filed 05/18/18 Page 14 of 24
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`82.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.264. Adobe denies that its products infringe the ʼ535 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately described the Adobe accused products.
`
`Adobe otherwise denies paragraph 82.
`
`83.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.264. Adobe denies that its products infringe the ʼ535 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately described the Adobe accused products.
`
`Adobe otherwise denies paragraph 83.
`
`84.
`
`85.
`
`86.
`
`87.
`
`88.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Adobe admits that it has had knowledge of the ʼ535 Patent since sometime after
`
`the filing of Realtime’s complaint. Adobe denies any remaining allegations of paragraph 88.
`
`89.
`
` Adobe admits that certain versions of certain of the accused products practice
`
`certain aspects of H.264. Adobe denies that any of its accused products infringe the ʼ535 Patent.
`
`Adobe denies the remaining allegations of paragraph 89.
`
`90.
`
`91.
`
`Denied.
`
`Denied.
`
`

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`Case 1:18-cv-10355-WGY Document 18 Filed 05/18/18 Page 15 of 24
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`92.
`
`Denied.
`
`COUNT V
`
`[ALLEGED] INFRINGEMENT OF U.S. PATENT NO. 9,578,298
`
`93.
`
`Adobe re-incorporates by reference all previous paragraphs as if fully set forth
`
`herein.
`
`94.
`
`Adobe admits that it has at times offered certain versions of Adobe Media
`
`Encoder, Media Encoder Creative Cloud, Media Encoder Creative Suite, Premiere Pro, Premiere
`
`Pro CC, Premiere Pro CS, After Effects, After Effects CC, and/or After Effects CS. Adobe
`
`denies that any of its products infringe the ʼ298 Patent. Adobe otherwise denies paragraph 94
`
`95.
`
`96.
`
`Denied.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.265. Adobe denies that its products infringe the ʼ298 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately described the Adobe accused products.
`
`Adobe otherwise denies paragraph 96.
`
`97.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.265 or “High Efficiency Video Coding.” Adobe denies that its products
`
`infringe the ʼ298 Patent. Adobe otherwise denies paragraph 97.
`
`98.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.265 or “High Efficiency Video Coding.” Adobe denies that its products
`
`infringe the ʼ298 Patent. Adobe otherwise denies paragraph 98.
`
`99.
`
`Adobe admits that certain versions of certain of the accused products support
`
`

`

`Case 1:18-cv-10355-WGY Document 18 Filed 05/18/18 Page 16 of 24
`
`certain aspects of H.265 or “High Efficiency Video Coding.” Adobe denies that its products
`
`infringe the ʼ298 Patent. Adobe otherwise denies paragraph 99.
`
`100.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.265 or “High Efficiency Video Coding.” Adobe denies that its products
`
`infringe the ʼ298 Patent. Adobe otherwise denies paragraph 100.
`
`101.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.265 or “High Efficiency Video Coding.” Adobe denies that its products
`
`infringe the ʼ298 Patent. Adobe otherwise denies paragraph 101.
`
`102.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.265 or “High Efficiency Video Coding.” Adobe denies that its products
`
`infringe the ʼ298 Patent. Adobe otherwise denies paragraph 102.
`
`103.
`
`104.
`
`105.
`
`106.
`
`107.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Adobe admits that it has had knowledge of the ʼ298 Patent since sometime after
`
`the filing of Realtime’s complaint. Adobe denies any remaining allegations in paragraph 107.
`
`108.
`
` Adobe admits that certain versions of certain of the accused products practice
`
`certain aspects of H.265. Adobe denies that any of its accused products infringe the ʼ298 Patent.
`
`Adobe denies any remaining allegations of paragraph 108.
`
`109.
`
`110.
`
`111.
`
`Denied.
`
`Denied.
`
`Denied.
`
`

`

`Case 1:18-cv-10355-WGY Document 18 Filed 05/18/18 Page 17 of 24
`
`COUNT VI
`
`[ALLEGED] INFRINGEMENT OF U.S. PATENT NO. 9,762,907
`
`112.
`
`Adobe re-incorporates by reference all previous paragraphs as if fully set forth
`
`herein.
`
`113.
`
`Adobe admits that it has at times offered certain versions of Adobe Media
`
`Encoder, Media Encoder Creative Cloud, Media Encoder Creative Suite, Premiere Pro, Premiere
`
`Pro CC, Premiere Pro CS, Flash, Flash Player, Flash Media Server, Flash Media Encoding
`
`Server, After Effects, After Effects CC, After Effects CS, and/or HTTP Dynamic Streaming
`
`(HDS). Adobe denies that any of its products infringe the ʼ907 Patent. Adobe otherwise denies
`
`paragraph 113.
`
`114.
`
`115.
`
`Denied.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.264. Adobe denies that its products infringe the ʼ907 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately described the Adobe accused products.
`
`Adobe otherwise denies paragraph 115.
`
`116.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.264. Adobe denies that its products infringe the ʼ907 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately described the Adobe accused products.
`
`Adobe otherwise denies paragraph 116.
`
`

`

`Case 1:18-cv-10355-WGY Document 18 Filed 05/18/18 Page 18 of 24
`
`117.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain types of compression. Adobe denies that its products infringe the ʼ907 Patent. Adobe
`
`denies that paragraph 117 accurately describes the Adobe accused products. Adobe otherwise
`
`denies paragraph 117.
`
`118.
`
`Realtime appears to have quoted from various websites, but Adobe denies that
`
`these websites are representative of how the accused instrumentalities operate. Adobe denies
`
`that its products infringe the ʼ907 Patent. Adobe otherwise denies paragraph 118.
`
`119.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain types of compression. Adobe denies that its products infringe the ʼ907 Patent. Adobe
`
`denies that paragraph 119 accurately describes the Adobe accused products. Adobe otherwise
`
`denies paragraph 119.
`
`120.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain types of compression. Adobe denies that its products infringe the ʼ907 Patent. Adobe
`
`denies that paragraph 120 accurately describes the Adobe accused products. Adobe otherwise
`
`denies paragraph 120.
`
`121.
`
`122.
`
`123.
`
`124.
`
`125.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Adobe admits that it has had knowledge of the ʼ907 Patent since sometime after
`
`the filing of Realtime’s complaint. Adobe denies any remaining allegations in paragraph 125.
`
`126.
`
`Adobe admits that certain versions of certain of the accused products practice
`
`certain aspects of H.264. Adobe denies that any of its accused products infringe the ʼ907 Patent.
`
`

`

`Case 1:18-cv-10355-WGY Document 18 Filed 05/18/18 Page 19 of 24
`
`Adobe denies the remaining allegations of paragraph 126.
`
`127.
`
`128.
`
`129.
`
`Denied.
`
`Denied.
`
`Denied.
`
`COUNT VII
`
`[ALLEGED] INFRINGEMENT OF U.S. PATENT NO. 9,769,477
`
`130.
`
`Adobe re-incorporates by reference all previous paragraphs as if fully set forth
`
`herein.
`
`131.
`
`Adobe admits that it has at times offered certain versions of Adobe Media
`
`Encoder, Media Encoder Creative Cloud, Media Encoder Creative Suite, Premiere Pro, Premiere
`
`Pro CC, Premiere Pro CS, Flash, Flash Player, Flash Media Server, Flash Media Encoding
`
`Server, After Effects, After Effects CC, After Effects CS, and/or HTTP Dynamic Streaming
`
`(HDS). Adobe denies that its products infringe the ʼ477 Patent. Adobe otherwise denies
`
`paragraph 131.
`
`132.
`
`133.
`
`Denied.
`
`Adobe admits that certain versions of certain of the accused products support
`
`certain aspects of H.264. Adobe denies that its products infringe the ʼ477 Patent. Realtime
`
`appears to have quoted from various websites. It is unclear why Realtime quoted these websites;
`
`to the extent it contends these websites support its claims of infringement, Adobe denies such
`
`allegations and denies that Realtime has accurately described the Adobe accused products.
`
`Adobe otherwise denies paragraph 133.
`
`134.
`
`Adobe admits tha