Case 2:23-cv-01161-MEF-LDW Document 23 Filed 06/26/23 Page 1 of 49 PageID: 1272
`
`
`Gregory S. Gewirtz
`ggewirtz@lernerdavid.com
`Russell W. Faegenburg
`rfaegenburg@lernerdavid.com
`Orville R. Cockings
`ocockings@lernerdavid.com
`Hoda Rifai-Bashjawish
`hrifai-bashjawish@lernerdavid.com
`Daniela Caro-Esposito
`dcaro-esposito@lernerdavid.com
`LERNER DAVID LLP
`20 Commerce Drive
`Cranford, NJ 07016
`Email: litigation@lernerdavid.com
`Tel:
`908.654.5000
`
`Attorneys for Defendant Sony Electronics Inc.
`
`
`UNITED STATES DISTRICT COURT
`DISTRICT OF JERSEY
`
`
`
`
`ANSWER, AFFIRMATIVE DEFENSES, AND COUNTERCLAIMS
`TO FIRST AMENDED COMPLAINT
`Defendant Sony Electronics Inc. (“Sony”), by and through its undersigned counsel,
`
`answers each numbered paragraph of the First Amended Complaint of Plaintiff Jawbone
`
`Innovations, LLC (“Jawbone”) as follows:
`
`THE PARTIES
`Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`1.
`
`the allegations contained in paragraph 1 of the Amended Complaint, and therefore denies them.
`
`Answer to First Amended Complaint (06_26_2023)(7716166.1).docx
`
`Document Filed Electronically
`
`Civil Action No. 2:23-cv-01161-CCC-LDW
`
`Michael E. Farbiarz, U.S.D.J.
`Leda Dunn Wettre, U.S.M.J
`
`
`:::::::x
`
`JAWBONE INNOVATIONS, LLC,
`
`
`Plaintiff,
`
`v.
`
`
`SONY ELECTRONICS INC.,
`
`
`Defendant.
`
`

`

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`2.
`
`Sony denies that it is a California corporation. Sony admits the remaining
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`allegations contained in paragraph 2 of the Amended Complaint.
`
`JURISDICTION AND VENUE
`Sony admits that the Amended Complaint purports to assert an action for patent
`
`3.
`
`infringement arising under the provisions of the Patent Laws of the United States of America, Title
`
`35, United States Code, but denies that it is liable for patent infringement. Sony denies that this
`
`Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1367. Sony admits the remaining
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`allegations contained in paragraph 3 of the Amended Complaint.
`
`4.
`
`Sony admits that specific and personal jurisdiction are proper in this Court and that
`
`it transacts business in New Jersey. Sony denies the remaining allegations contained in paragraph 4
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`of the Amended Complaint.
`
`5.
`
`Sony admits that venue is proper in this Court. Sony denies the remaining
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`allegations contained in paragraph 5 of the Amended Complaint.
`
`FACTUAL BACKGROUND
`Sony admits that the ’091 Patent was issued on September 13, 2011, has the title
`
`6.
`
`identified in paragraph 6 of the Amended Complaint, and that a copy of the ’091 Patent is
`
`identified in the Amended Complaint as Exhibit A. Sony lacks knowledge or information
`
`sufficient to form a belief as to the truth of the remaining allegations of paragraph 6 of the
`
`Amended Complaint, and therefore denies them.
`
`7.
`
`Sony admits that the ’058 Patent was issued on July 17, 2007, has the title identified
`
`in paragraph 7 of the Amended Complaint, and that a copy of the ’058 Patent is identified in the
`
`Amended Complaint as Exhibit B. Sony lacks knowledge or information sufficient to form a belief
`
`as to the truth of the remaining allegations of paragraph 7 of the Amended Complaint, and
`
`therefore denies them.
`
`
`
`2
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`

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`8.
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`Sony admits that the ’080 Patent was issued on September 15, 2020, has the title
`
`identified in paragraph 8 of the Amended Complaint, and that a copy of the ’080 Patent is
`
`identified in the Amended Complaint as Exhibit C. Sony lacks knowledge or information sufficient
`
`to form a belief as to the truth of the remaining allegations of paragraph 8 of the Amended
`
`Complaint, and therefore denies them.
`
`9.
`
`Sony admits that the ’357 Patent was issued on September 14, 2021, has the title
`
`identified in paragraph 9 of the Amended Complaint, and that a copy of the ’357 Patent is
`
`identified in the Amended Complaint as Exhibit D. Sony lacks knowledge or information
`
`sufficient to form a belief as to the truth of the remaining allegations of paragraph 9 of the
`
`Amended Complaint, and therefore denies them.
`
`10.
`
`Sony admits that the ’543 Patent was issued on June 18, 2013, has the title identified
`
`in paragraph 10 of the Amended Complaint, and that a copy of the ’543 Patent is identified in the
`
`Amended Complaint as Exhibit E. Sony lacks knowledge or information sufficient to form a belief
`
`as to the truth of the remaining allegations of paragraph 10 of the Amended Complaint, and
`
`therefore denies them.
`
`11.
`
`Sony admits that the ’691 Patent was issued on August 6, 2013, has the title
`
`identified in paragraph 11 of the Amended Complaint, and that a copy of the ’691 Patent is
`
`identified in the Amended Complaint as Exhibit F. Sony lacks knowledge or information sufficient
`
`to form a belief as to the truth of the remaining allegations of paragraph 11 of the Amended
`
`Complaint, and therefore denies them.
`
`12.
`
`Sony admits that the ’213 Patent was issued on November 27, 2012, has the title
`
`identified in paragraph 12 of the Amended Complaint, and that a copy of the ’213 Patent is
`
`identified in the Amended Complaint as Exhibit G. Sony lacks knowledge or information sufficient
`
`
`
`3
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`

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`to form a belief as to the truth of the remaining allegations of paragraph 12 of the Amended
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`Complaint, and therefore denies them.
`
`13.
`
`Sony admits that the ’611 Patent was issued on December 4, 2012, has the title
`
`identified in paragraph 13 of the Amended Complaint, and that a copy of the ’611 Patent is
`
`identified in the Amended Complaint as Exhibit H. Sony lacks knowledge or information sufficient
`
`to form a belief as to the truth of the remaining allegations of paragraph 13 of the Amended
`
`Complaint, and therefore denies them.
`
`14.
`
`Sony admits that the ’327 Patent was issued on February 26, 2019, has the title
`
`identified in paragraph 14 of the Amended Complaint, and that a copy of the ’327 Patent is
`
`identified in the Amended Complaint as Exhibit I. Sony lacks knowledge or information sufficient
`
`to form a belief as to the truth of the remaining allegations of paragraph 14 of the Amended
`
`Complaint, and therefore denies them.
`
`15.
`
`Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 15 of the Amended Complaint, and therefore denies them.
`
`16.
`
`Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 16 of the Amended Complaint, and therefore denies them.
`
`17.
`
`Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 17 of the Amended Complaint, and therefore denies them.
`
`18.
`
`Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 18 of the Amended Complaint, and therefore denies them.
`
`19.
`
`Sony admits it received correspondence regarding the availability of Jawbone’s
`
`patent portfolio for potential purchase but denies that Sony was notified of any potential
`
`infringement of the Accused Products under any of the Patents-in-Suit and denies any Sony
`
`
`
`4
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`

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`Accused Products infringe any of the Patents-in-Suit. Sony denies the remaining allegations of
`
`paragraph 19 of the Amended Complaint.
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`INFRINGEMENT ALLEGATIONS
`
`20.
`
`Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the remaining allegations of paragraph 20 of the Amended Complaint, and therefore denies them.
`
`21.
`
`Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 21 of the Amended Complaint, and therefore denies them.
`
`22.
`
`Sony admits that it sells earbuds such as WF-1000XM4, headphones, and
`
`beamformer microphones. Sony denies the remaining allegations of paragraph 22 of the Amended
`
`Complaint.
`
`23.
`
`Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 23 of the Amended Complaint, and therefore denies them.
`
`24.
`
`25.
`
`Sony denies the allegations of paragraph 24 of the Amended Complaint.
`
`Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations of paragraph 25 of the Amended Complaint, and therefore denies them.
`
`26.
`
`27.
`
`Sony denies the allegations of paragraph 26 of the Amended Complaint.
`
`Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the remaining allegations of paragraph 27 of the Amended Complaint, and therefore denies them.
`
`28.
`
`29.
`
`Sony denies the allegations of paragraph 28 of the Amended Complaint.
`
`Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the remaining allegations of paragraph 29 of the Amended Complaint, and therefore denies them.
`
`30.
`
`Sony denies the allegations of paragraph 30 of the Amended Complaint.
`
`
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`5
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`

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`31.
`
`Sony lacks knowledge or information to form a belief as to the truth of the
`
`allegations contained in paragraph 31 of the Amended Complaint, and therefore denies them.
`
`32.
`
`33.
`
`Sony denies the allegations of paragraph 32 of the Amended Complaint.
`
`Sony lacks knowledge or information to form a belief as to the truth of the
`
`allegations contained in paragraph 33 of the Amended Complaint, and therefore denies them.
`
`34.
`
`Sony denies the allegations of paragraph 34 of the Amended Complaint.
`
`COUNT I
`(Infringement of the ’091 Patent)
`
`35.
`
`36.
`
`Sony incorporates by reference its responses to paragraphs 1 through 34.
`
`Sony admits it has not entered into a license agreement with Jawbone. Sony lacks
`
`knowledge or information sufficient to form a belief as to the truth of the remaining allegations
`
`contained in paragraph 36 of the Amended Complaint, and therefore denies them.
`
`37.
`
`38.
`
`39.
`
`Sony denies the allegations of paragraph 37 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 38 of the Amended Complaint.
`
`Sony admits that “uses beamforming microphones . . . to allow the WF-1000XM4
`
`headphones to pick up your voice clearly and accurately for hands-free calls” is an accurate quote
`
`from the website cited in footnote 16 of paragraph 39 of the Amended Complaint. Sony lacks
`
`knowledge or information sufficient to form a belief as to the truth of the remaining allegations of
`
`paragraph 36 of the Amended Complaint, and therefore denies them.
`
`40.
`
`Sony admits that the image provided with paragraph 40 accurately reflects an image
`
`and text relating to the WF-1000XM4 product from the website cited in footnote 17 of
`
`paragraph 40 of the Amended Complaint. Sony lacks knowledge or information sufficient to form
`
`a belief as to the truth of the remaining allegations of paragraph 40 of the Amended Complaint,
`
`and therefore denies them.
`
`
`
`6
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`

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`41.
`
`Sony admits that the WF-1000XM4 product contains an accelerometer and a bone
`
`conduction sensor. Sony lacks knowledge or information sufficient to form a belief as to the truth
`
`of the remaining allegations of paragraph 41 of the Amended Complaint, and therefore denies
`
`them.
`
`42.
`
`Sony admits that at least some of the Accused Products include an Integrated
`
`Processor V1 and microphones. Sony lacks knowledge or information sufficient to form a belief
`
`as to the truth of the remaining allegations contained in paragraph 42 of the Amended Complaint,
`
`and therefore denies them.
`
`43.
`
`Sony admits that the WF-1000XM4 product contains an accelerometer and a bone
`
`conduction sensor. Sony lacks knowledge or information sufficient to form a belief as to the truth
`
`of the remaining allegations contained in paragraph 43 of the Amended Complaint, and therefore
`
`denies them.
`
`44.
`
`Sony admits that the WF-1000XM4 product contains an accelerometer and a bone
`
`conduction sensor. Sony lacks knowledge or information sufficient to form a belief as to the truth
`
`of the remaining allegations contained in paragraph 44 of the Amended Complaint, and therefore
`
`denies them.
`
`45.
`
`Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 45 of the Amended Complaint, and therefore denies them.
`
`46.
`
`47.
`
`48.
`
`49.
`
`50.
`
`Sony denies the allegations of paragraph 46 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 47 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 48 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 49 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 50 of the Amended Complaint.
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`
`
`7
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`

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`51.
`
`Sony denies the allegations of paragraph 51 of the Amended Complaint.
`
`
`
`COUNT II
`(Infringement of the ’058 Patent)
`
`52.
`
`53.
`
`Sony incorporates by reference its responses to paragraphs 1 through 34.
`
`Sony admits it has not entered into a license agreement with Jawbone. Sony lacks
`
`knowledge or information sufficient to form a belief as to the truth of the remaining allegations
`
`contained in paragraph 53 of the Amended Complaint, and therefore denies them.
`
`54.
`
`55.
`
`56.
`
`Sony denies the allegations of paragraph 54 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 55 of the Amended Complaint.
`
`Sony admits the Sony WF-1000XM4 contains microphones. Sony lacks knowledge
`
`or information sufficient to form a belief as to the truth of the remaining allegations contained in
`
`paragraph 56 of the Amended Complaint, and therefore denies them.
`
`57.
`
`Sony admits the Sony WF-1000XM4 contains an accelerometer. Sony lacks
`
`knowledge or information sufficient to form a belief as to the truth of the remaining allegations
`
`contained in paragraph 57 of the Amended Complaint, and therefore denies them.
`
`58.
`
`Sony admits the Sony WF-1000XM4 contains an Integrated Processor V1,
`
`microphones, and an accelerometer. Sony lacks knowledge or information sufficient to form a
`
`belief as to the truth of the remaining allegations contained in paragraph 58 of the Amended
`
`Complaint, and therefore denies them.
`
`59.
`
`Sony admits the Sony WF-1000XM4 contains an Integrated Processor V1 and
`
`microphones. Sony lacks knowledge or information sufficient to form a belief as to the truth of the
`
`remaining allegations contained in paragraph 59 of the Amended Complaint, and therefore denies
`
`them.
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`8
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`60.
`
`Sony admits the Sony WF-1000XM4 contains an Integrated Processor V1 and
`
`microphones. Sony lacks knowledge or information sufficient to form a belief as to the truth of the
`
`remaining allegations contained in paragraph 60 of the Amended Complaint, and therefore denies
`
`them.
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`61.
`
`Sony admits the Sony WF-1000XM4 contains an Integrated Processor V1 and
`
`microphones. Sony lacks knowledge or information sufficient to form a belief as to the truth of the
`
`remaining allegations contained in paragraph 61 of the Amended Complaint, and therefore denies
`
`them.
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`62.
`
`Sony admits the Sony WF-1000XM4 contains an Integrated Processor V1. Sony
`
`lacks knowledge or information sufficient to form a belief as to the truth of the remaining
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`allegations contained in paragraph 62 of the Amended Complaint, and therefore denies them.
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`63.
`
`Sony admits the Sony WF-1000XM4 contains an Integrated Processor V1. Sony
`
`lacks knowledge or information sufficient to form a belief as to the truth of the remaining
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`allegations contained in paragraph 63 of the Amended Complaint, and therefore denies them.
`
`64.
`
`65.
`
`66.
`
`67.
`
`68.
`
`69.
`
`Sony denies the allegations of paragraph 64 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 65 of the Amended Complaint.
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`Sony denies the allegations of paragraph 66 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 67 of the Amended Complaint.
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`Sony denies the allegations of paragraph 68 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 69 of the Amended Complaint.
`
`COUNT III
`(Infringement of the ’080 Patent)
`
`70.
`
`Sony incorporates by reference its responses to paragraphs 1 through 34.
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`9
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`71.
`
`Sony admits it has not entered into a license agreement with Jawbone. Sony lacks
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`knowledge or information sufficient to form a belief as to the truth of the remaining allegations
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`contained in paragraph 71 of the Amended Complaint, and therefore denies them.
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`72.
`
`73.
`
`74.
`
`Sony denies the allegations of paragraph 72 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 73 of the Amended Complaint.
`
`Sony admits the Sony WF-1000XM4 contains microphones. Sony lacks knowledge
`
`or information sufficient to form a belief as to the truth of the remaining allegations contained in
`
`paragraph 74 of the Amended Complaint, and therefore denies them.
`
`75.
`
`Sony admits the Sony WF-1000XM4 contains an Integrated Processor V1 and
`
`microphones. Sony lacks knowledge or information sufficient to form a belief as to the truth of the
`
`remaining allegations contained in paragraph 75 of the Amended Complaint, and therefore denies
`
`them.
`
`76.
`
`Sony admits the Sony WF-1000XM4 contains microphones. Sony lacks knowledge
`
`or information sufficient to form a belief as to the truth of the remaining allegations contained in
`
`paragraph 76 of the Amended Complaint, and therefore denies them.
`
`77.
`
`Sony admits the Sony WF-1000XM4 contains microphones. Sony lacks knowledge
`
`or information sufficient to form a belief as to the truth of the remaining allegations contained in
`
`paragraph 77 of the Amended Complaint, and therefore denies them.
`
`78.
`
`Sony admits the Sony WF-1000XM4 contains an Integrated Processor V1 and
`
`microphones. Sony lacks knowledge or information sufficient to form a belief as to the truth of the
`
`remaining allegations contained in paragraph 78 of the Amended Complaint, and therefore denies
`
`them.
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`10
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`79.
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`Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 79 of the Amended Complaint, and therefore denies them.
`
`80.
`
`81.
`
`82.
`
`83.
`
`84.
`
`85.
`
`86.
`
`Sony denies the allegations of paragraph 80 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 81 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 82 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 83 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 84 of the Amended Complaint.
`
`COUNT IV
`(Infringement of the ’357 Patent)
`
`Sony incorporates by reference its responses to paragraphs 1 through 34.
`
`Sony admits it has not entered into a license agreement with Jawbone. Sony lacks
`
`knowledge or information sufficient to form a belief as to the truth of the remaining allegations
`
`contained in paragraph 86 of the Amended Complaint, and therefore denies them.
`
`87.
`
`88.
`
`89.
`
`Sony denies the allegations of paragraph 87 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 88 of the Amended Complaint.
`
`Sony admits the Sony WF-1000XM4 contains microphones. Sony lacks knowledge
`
`or information sufficient to form a belief as to the truth of the remaining allegations contained in
`
`paragraph 89 of the Amended Complaint, and therefore denies them.
`
`90.
`
`Sony admits the Sony WF-1000XM4 contains microphones. Sony lacks knowledge
`
`or information sufficient to form a belief as to the truth of the remaining allegations contained in
`
`paragraph 90 of the Amended Complaint, and therefore denies them.
`
`91.
`
`Sony admits the Sony WF-1000XM4 contains microphones. Sony lacks knowledge
`
`or information sufficient to form a belief as to the truth of the remaining allegations contained in
`
`paragraph 91 of the Amended Complaint, and therefore denies them.
`
`
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`11
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`92.
`
`Sony admits the Sony WF-1000XM4 contains an Integrated Processor V1and
`
`microphones. Sony lacks knowledge or information sufficient to form a belief as to the truth of the
`
`remaining allegations contained in paragraph 92 of the Amended Complaint, and therefore denies
`
`them.
`
`93.
`
`94.
`
`95.
`
`96.
`
`97.
`
`98.
`
`99.
`
`Sony denies the allegations of paragraph 93 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 94 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 95 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 96 of the Amended Complaint.
`
`Sony denies the allegations of paragraph 97 of the Amended Complaint.
`
`COUNT V
`(Infringement of the ’543 Patent)
`
`Sony incorporates by reference its responses to paragraphs 1 through 34.
`
`Sony admits it has not entered into a license agreement with Jawbone. Sony lacks
`
`knowledge or information sufficient to form a belief as to the truth of the remaining allegations
`
`contained in paragraph 99 of the Amended Complaint, and therefore denies them.
`
`100. Sony denies the allegations of paragraph 100 of the Amended Complaint.
`
`101. Sony denies the allegations of paragraph 101 of the Amended Complaint.
`
`102. Sony admits the Sony WF-1000XM4 contains an accelerometer. Sony lacks
`
`knowledge or information sufficient to form a belief as to the truth of the remaining allegations
`
`contained in paragraph 102 of the Amended Complaint, and therefore denies them.
`
`103. Sony admits the Sony WF-1000XM4 contains an accelerometer and microphones.
`
`Sony lacks knowledge or information sufficient to form a belief as to the truth of the remaining
`
`allegations contained in paragraph 103 of the Amended Complaint, and therefore denies them.
`
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`12
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`104. Sony admits the Sony WF-1000XM4 contains microphones. Sony lacks knowledge
`
`or information sufficient to form a belief as to the truth of the remaining allegations contained in
`
`paragraph 104 of the Amended Complaint, and therefore denies them.
`
`105. Sony admits the Sony WF-1000XM4 contains microphones. Sony lacks knowledge
`
`or information sufficient to form a belief as to the truth of the remaining allegations contained in
`
`paragraph 105 of the Amended Complaint, and therefore denies them.
`
`106. Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 106 of the Amended Complaint, and therefore denies them.
`
`107. Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 107 of the Amended Complaint, and therefore denies them.
`
`108. Sony admits the Sony WF-1000XM4 contains an accelerometer and microphones.
`
`Sony lacks knowledge or information sufficient to form a belief as to the truth of the remaining
`
`allegations contained in paragraph 108 of the Amended Complaint, and therefore denies them.
`
`109. Sony denies the allegations of paragraph 109 of the Amended Complaint.
`
`110. Sony denies the allegations of paragraph 110 of the Amended Complaint.
`
`111. Sony denies the allegations of paragraph 111 of the Amended Complaint.
`
`112. Sony denies the allegations of paragraph 112 of the Amended Complaint.
`
`113. Sony denies the allegations of paragraph 113 of the Amended Complaint.
`
`114. Sony denies the allegations of paragraph 114 of the Amended Complaint.
`
`COUNT VI
`(Infringement of the ’691 Patent)
`
`115. Sony incorporates by reference its responses to paragraphs 1 through 34.
`
`
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`13
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`116. Sony admits it has not entered into a license agreement with Jawbone. Sony lacks
`
`knowledge or information sufficient to form a belief as to the truth of the remaining allegations
`
`contained in paragraph 116 of the Amended Complaint, and therefore denies them.
`
`117. Sony denies the allegations of paragraph 117 of the Amended Complaint.
`
`118. Sony denies the allegations of paragraph 118 of the Amended Complaint.
`
`119. Sony admits the Sony WF-1000XM4 contains microphones. Sony lacks knowledge
`
`or information sufficient to form a belief as to the truth of the remaining allegations contained in
`
`paragraph 119 of the Amended Complaint, and therefore denies them.
`
`120. Sony admits the Sony WF-1000XM4 contains microphones. Sony lacks knowledge
`
`or information sufficient to form a belief as to the truth of the remaining allegations contained in
`
`paragraph 120 of the Amended Complaint, and therefore denies them.
`
`121. Sony admits the Sony WF-1000XM4 contains microphones. Sony lacks knowledge
`
`or information sufficient to form a belief as to the truth of the remaining allegations contained in
`
`paragraph 121 of the Amended Complaint, and therefore denies them.
`
`122. Sony admits the Sony WF-1000XM4 contains microphones. Sony lacks knowledge
`
`or information sufficient to form a belief as to the truth of the remaining allegations contained in
`
`paragraph 122 of the Amended Complaint, and therefore denies them.
`
`123. Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 123 of the Amended Complaint, and therefore denies them.
`
`124. Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 124 of the Amended Complaint, and therefore denies them.
`
`125. Sony denies the allegations of paragraph 125 of the Amended Complaint.
`
`126. Sony denies the allegations of paragraph 126 of the Amended Complaint.
`
`
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`14
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`127. Sony denies the allegations of paragraph 127 of the Amended Complaint.
`
`128. Sony denies the allegations of paragraph 128 of the Amended Complaint.
`
`129. Sony denies the allegations of paragraph 129 of the Amended Complaint.
`
`130. Sony denies the allegations of paragraph 130 of the Amended Complaint.
`
`
`
`COUNT VII
`(Infringement of the ’213 Patent)
`
`131. Sony incorporates by reference its responses to paragraphs 1 through 34.
`
`132. Sony admits it has not entered into a license agreement with Jawbone. Sony lacks
`
`knowledge or information sufficient to form a belief as to the truth of the remaining allegations
`
`contained in paragraph 132 of the Amended Complaint, and therefore denies them.
`
`133. Sony denies the allegations of paragraph 133 of the Amended Complaint.
`
`134. Sony denies the allegations of paragraph 134 of the Amended Complaint.
`
`135. Sony admits the Sony WF-1000XM4 and the Sony LF-S50G each contains
`
`microphones. Sony lacks knowledge or information sufficient to form a belief as to the truth of the
`
`remaining allegations contained in paragraph 135 of the Amended Complaint, and therefore denies
`
`them.
`
`136. Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 136 of the Amended Complaint, and therefore denies them.
`
`137. Sony admits the Sony WF-1000XM4 and the Sony LF-S50G each contains
`
`microphones. Sony lacks knowledge or information sufficient to form a belief as to the truth of the
`
`remaining allegations contained in paragraph 137 of the Amended Complaint, and therefore denies
`
`them.
`
`
`
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`138. Sony admits the Sony WF-1000XM4 and the Sony LF-S50G each contains
`
`microphones. Sony lacks knowledge or information sufficient to form a belief as to the truth of the
`
`remaining allegations contained in paragraph 138 of the Amended Complaint, and therefore denies
`
`them.
`
`139. Sony denies the allegations of paragraph 139 of the Amended Complaint.
`
`140. Sony denies the allegations of paragraph 140 of the Amended Complaint.
`
`141. Sony denies the allegations of paragraph 141 of the Amended Complaint.
`
`142. Sony denies the allegations of paragraph 142 of the Amended Complaint.
`
`143. Sony denies the allegations of paragraph 143 of the Amended Complaint.
`
`144. Sony denies the allegations of paragraph 144 of the Amended Complaint.
`
`COUNT VIII
`(Infringement of the ’611 Patent)
`
`145. Sony incorporates by reference its responses to paragraphs 1 through 34.
`
`146. Sony admits it has not entered into a license agreement with Jawbone. Sony lacks
`
`knowledge or information sufficient to form a belief as to the truth of the remaining allegations
`
`contained in paragraph 146 of the Amended Complaint, and therefore denies them.
`
`147. Sony denies the allegations of paragraph 147 of the Amended Complaint.
`
`148. Sony denies the allegations of paragraph 148 of the Amended Complaint.
`
`149. Sony admits the Sony WF-1000XM4 and the Sony LF-S50G each contains
`
`microphones. Sony lacks knowledge or information sufficient to form a belief as to the truth of the
`
`remaining allegations contained in paragraph 149 of the Amended Complaint, and therefore denies
`
`them.
`
`150. Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 150 of the Amended Complaint, and therefore denies them.
`
`
`
`16
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`151. Sony admits the Sony WF-1000XM4 and the Sony LF-S50G each contains
`
`microphones. Sony lacks knowledge or information sufficient to form a belief as to the truth of the
`
`remaining allegations contained in paragraph 151 of the Amended Complaint, and therefore denies
`
`them.
`
`152. Sony admits the Sony WF-1000XM4 and the Sony LF-S50G each contains
`
`microphones. Sony lacks knowledge or information sufficient to form a belief as to the truth of the
`
`remaining allegations contained in paragraph 152 of the Amended Complaint, and therefore denies
`
`them.
`
`153. Sony denies the allegations of paragraph 153 of the Amended Complaint.
`
`154. Sony denies the allegations of paragraph 154 of the Amended Complaint.
`
`155. Sony denies the allegations of paragraph 155 of the Amended Complaint.
`
`156. Sony denies the allegations of paragraph 156 of the Amended Complaint.
`
`157. Sony denies the allegations of paragraph 157 of the Amended Complaint.
`
`158. Sony denies the allegations of paragraph 158 of the Amended Complaint.
`
`COUNT IX
`(Infringement of the '327 Patent)
`
`159. Sony incorporates by reference its responses to paragraphs 1 through 34.
`
`160. Sony admits it has not entered into a license agreement with Jawbone. Sony lacks
`
`knowledge or information sufficient to form a belief as to the truth of the remaining allegations
`
`contained in paragraph 160 of the Amended Complaint, and therefore denies them.
`
`161. Sony denies the allegations of paragraph 161 of the Amended Complaint.
`
`162. Sony denies the allegations of paragraph 162 of the Amended Complaint.
`
`163. Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 163 of the Amended Complaint, and therefore denies them.
`
`
`
`17
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`164. Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 164 of the Amended Complaint, and therefore denies them.
`
`165. Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 165 of the Amended Complaint, and therefore denies them.
`
`166. Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 166 of the Amended Complaint, and therefore denies them.
`
`167. Sony lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in paragraph 167 of the Amended Complaint, and there