UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF PENNSYLVANIA
`
`THE PNC FINANCIAL SERVICES
`
`GROUP, INC., and
`PNC BANK, NATIONAL ASSOCIATION,
`
`Plaintiffs,
`
`v.
`
`MAXIM INTEGRATED PRODUCTS, INC.,
`
`Defendant.
`
`\/%\.J\_/€\_/%%\/%%\/%
`
`Civil Action No. 12-89-NBF
`
`Judge Nora Barry Fischer
`
`Filed Electronically
`
`MAXIM INTEGRATED PRODUCTS, INC.’S ANSWER TO CONIPLAINT FOR
`DECLARATORY JUDGMENT AND COUNTERCLAIMS
`
`Defendant Maxim Integrated Products,
`
`Inc.
`
`(“Maxim”), by its undersigned
`
`attorneys, hereby answers the Complaint of Plaintiffs, The PNC Financial Services Group,
`
`Inc. and PNC Bank, National Association (collectively “PNC”), as set forth below. Except
`
`where specifically admitted herein, Maxim denies the allegations in the Complaint.
`
`NATURE OF ACTION
`
`1.
`
`Maxim admits the Complaint seeks a declaration of non—infringement and
`
`invalidity of U.S. Patent No. 5,940,510 (“the ’510 Patent”), U.S. Patent No. 5,949,880 (“the
`
`’880 Patent”), U.S. Patent No. 6,105,013 (“the ’013 Patent”) and U.S. Patent No. 6,237,095
`
`(“the ’095 patent”) (collectively, the “Asserted Patents”). Except as specifically admitted,
`
`Maxim denies the remaining allegations of paragraph 1.
`
`2.
`
`Maxim lacks knowledge or information sufficient to form a belief about the
`
`THE PARTIES
`
`truth of the allegations of paragraph 2, and thus denies them.
`
`Page 1 of 15
`
`PNC-JP MORGAN EXHIBIT 1006
`
`PNC-JP MORGAN EXHIBIT 1006
`
`
`FOR THE WESTERN DISTRICT OF PENNSYLVANIA
`
`THE PNC FINANCIAL SERVICES
`
`GROUP, INC., and
`PNC BANK, NATIONAL ASSOCIATION,
`
`Plaintiffs,
`
`v.
`
`MAXIM INTEGRATED PRODUCTS, INC.,
`
`Defendant.
`
`\/%\.J\_/€\_/%%\/%%\/%
`
`Civil Action No. 12-89-NBF
`
`Judge Nora Barry Fischer
`
`Filed Electronically
`
`MAXIM INTEGRATED PRODUCTS, INC.’S ANSWER TO CONIPLAINT FOR
`DECLARATORY JUDGMENT AND COUNTERCLAIMS
`
`Defendant Maxim Integrated Products,
`
`Inc.
`
`(“Maxim”), by its undersigned
`
`attorneys, hereby answers the Complaint of Plaintiffs, The PNC Financial Services Group,
`
`Inc. and PNC Bank, National Association (collectively “PNC”), as set forth below. Except
`
`where specifically admitted herein, Maxim denies the allegations in the Complaint.
`
`NATURE OF ACTION
`
`1.
`
`Maxim admits the Complaint seeks a declaration of non—infringement and
`
`invalidity of U.S. Patent No. 5,940,510 (“the ’510 Patent”), U.S. Patent No. 5,949,880 (“the
`
`’880 Patent”), U.S. Patent No. 6,105,013 (“the ’013 Patent”) and U.S. Patent No. 6,237,095
`
`(“the ’095 patent”) (collectively, the “Asserted Patents”). Except as specifically admitted,
`
`Maxim denies the remaining allegations of paragraph 1.
`
`2.
`
`Maxim lacks knowledge or information sufficient to form a belief about the
`
`THE PARTIES
`
`truth of the allegations of paragraph 2, and thus denies them.
`
`Page 1 of 15
`
`PNC-JP MORGAN EXHIBIT 1006
`
`PNC-JP MORGAN EXHIBIT 1006
`
`
`
`3.
`
`Maxim lacks knowledge or information sufficient to form a belief about the
`
`truth of the allegations of paragraph 3, and thus denies them.
`
`4.
`
`Maxim admits the allegations of paragraph 4.
`
`JURISDICTION AND VENUE
`
`5.
`
`Maxim admits that the allegations in the Complaint arise under the patent
`
`laws of Title 35 of the United States Code, § 100 et seq., and that the Complaint seeks a
`
`remedy under the Declaratory Judgment Act, 28 U.S.C. §§ 2201 and 2202. Maxim admits
`
`that subject matter jurisdiction is proper under 28 U.S.C. §§ 1331 and l338(a). Maxim
`
`admits that an actual controversy exists between the parties. Except as specifically
`
`admitted, Maxim denies the remaining allegations of paragraph 5.
`
`6.
`
`7.
`
`8.
`
`Maxim admits the allegations of paragraph 6.
`
`Maxim admits the allegations of paragraph 7.
`
`Maxim admits that the document attached to the Complaint as Exhibit A
`
`appears to be a true and correct copy of a printout from Maxim’s website showing “Maxim
`
`Sales Offices” at various locations around the world. Maxim admits that the document
`
`attached to the Complaint as Exhibit A includes a telephone number for a sales office
`
`corresponding to Pennsylvania and a telephone number
`
`for a sales representative
`
`corresponding to Pennsylvania.
`
`Except as specifically admitted, Maxim denies the
`
`remaining allegations of paragraph 8.
`
`9.
`
`Maxim admits that the document attached to the Complaint as Exhibit B
`
`appears to be a true and correct copy of a printout from Maxim’s website showing three
`
`franchised distributors associated with Pennsylvania. Maxim admits that the page lists a
`
`Page 2 of 15
`
`
`
`location for the franchised distributor Avnet
`
`in Wexford, Pennsylvania.
`
`Except as
`
`specifically admitted, Maxim denies the remaining allegations of paragraph 9.
`
`10.
`
`Maxim admits the allegations of paragraph 10.
`
`11.
`
`Maxim admits the allegations of paragraph 11.
`
`12. Without prejudice to its other rights, and fully reserving the same, Maxim
`
`admits that venue is proper in this judicial district for purposes of trial.‘ Except as
`
`specifically admitted, Maxim denies the remaining allegations of paragraph 12.
`
`13.
`
`Maxim admits the allegations of paragraph 13.
`
`BACKGROUND
`
`14.
`
`Maxim admits that the Asserted Patents are assigned to Maxim. Maxim
`
`admits that the documents attached as Exhibits C, D, E, and F to the Complaint appear to be
`
`true and correct copies of the Asserted Patents. Maxim admits that the documents attached
`
`as Exhibits G, H, I, and J appear to be true and correct copies of the patent assignment
`
`abstracts of title for the Asserted Patents. Except as specifically admitted, Maxim denies
`
`the remaining allegations of paragraph 14.
`
`15.
`
`Maxim admits the allegations of paragraph 15.
`
`16.
`
`Maxim admits the allegations of paragraph 16.
`
`17.
`
`Maxim denies the allegations of paragraph 17.
`
`18.
`
`Maxim admits the allegations of paragraph 18.
`
`19.
`
`Maxim admits the allegations of paragraph 19.
`
`1 Maxim has filed a Motion for Transfer and Consolidation Pursuant to 28 U.S.C. §
`1407 with the United States Judicial Panel on Multidistrict Litigation (“JPML”). See
`MDL No. 2354. Maxim believes that the Eastern District of Texas is a proper venue for
`all pretrial proceedings. Oral Arguments in connection with the Transfer Motion were
`heard by the JPML on May 31, 2012.
`
`Page 3 of 15
`
`
`
`20.
`
`Maxim denies the allegations of paragraph 20.
`
`21.
`
`Maxim admits the allegations of paragraph 21.
`
`22.
`
`No response to paragraph 22 is required, as it merely characterizes PNC’s
`
`perceptions of Maxim’s intent.
`
`COUNT I: DECLARATORY JUDGMENT OF NON-INFRINGEMENT
`
`23.
`
`Maxim incorporates by reference its responses to paragraphs 1-22.
`
`24.
`
`Maxim denies the allegations of paragraph 24.
`
`25.
`
`Maxim denies the allegations of paragraph 25.
`
`26.
`
`Maxim denies the allegations of paragraph 26.
`
`27.
`
`Maxim denies the allegations of paragraph 27.
`
`28.
`
`Maxim denies the allegations of paragraph 28 and avers that PNC is not
`
`entitled to any relief.
`
`COUNT II: DECLARATORY JUDGMENT OF NON-INFRINGEMENT
`
`29.
`
`Maxim incorporates by reference its responses to paragraphs 1-28.
`
`30.
`
`Maxim denies the allegations of paragraph 30.
`
`31.
`
`Maxim denies the allegations of paragraph 31 and avers that PNC is not
`
`entitled to any relief.
`
`PRAYER FOR RELIEF
`
`Maxim denies that PNC is entitled to any relief, including the relief prayed for in
`
`paragraphs a) — g) under the heading “PRAYER FOR RELIEF.”
`
`Page 4 of 15
`
`
`
`JURY DEMAND
`
`Maxim admits that PNC has requested a trial by jury on all issues so triable. Except as
`
`specifically admitted, Maxim denies the remaining allegations under the heading “JURY
`
`DEMAND.”
`
`COUNTERCLAIMS
`
`Counterclaimant Maxim Integrated Products, Inc. (“Maxim”) hereby alleges for its
`
`Counterclaims against Counter-Defendants The PNC Financial Services Group, Inc. and
`
`PNC Bank, National Association (collectively “PNC”), on personal knowledge as to its
`
`own actions and on information and belief as to the actions of others, as follows:
`
`THE PARTIES
`
`1.
`
`Counterclaimant Maxim is a Delaware Corporation with its principal place
`
`of business at 120 San Gabriel Drive, Sunnyvale, California 94086.
`
`2.
`
`On information and belief, Counter-Defendant The PNC Financial Services
`
`Group, Inc., is a Pennsylvania corporation with its principal place of business in Pittsburgh,
`
`Pennsylvania.
`
`3.
`
`On information and belief, Counter-Defendant PNC Bank, National
`
`Association,
`
`is a national banking association with its principal place of business in
`
`Pittsburgh, Pennsylvania. PNC Bank, National Association is a wholly-owned, indirect
`
`subsidiary of The PNC Financial Services Group, Inc.
`
`Page 5 of 15
`
`
`
`JURISDICTION AND VENUE
`
`4.
`
`This action arises under the patent laws of the United States, Title 35 of the
`
`United States Code.
`
`5.
`
`This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and
`
`1338(a).
`
`6.
`
`This Court has personal
`
`jurisdiction over PNC because PNC has its
`
`principal place of business in this District.
`
`In addition, PNC has offered for sale, sold,
`
`and/or advertised its products and services in this District. Thus, PNC has committed and
`
`continues to commit acts of patent infringement in this District. Additionally, PNC has
`
`submitted to jurisdiction in this District by initiating a declaratory judgment action against
`
`Maxim in this District.
`
`7.
`
`Without prejudice to its other rights, and fully reserving the same, venue is
`
`proper in this District under 28 U.S.C. §§ 1391(b) and (c), and 1400(b).2
`
`THE ASSERTED PATENTS
`
`8.
`
`On August 17, 1999, the United States Patent and Trademark Office duly
`
`and legally issued U.S. Patent No. 5,940,510 (“the ’510 Patent”), entitled “Transfer of
`
`Valuable Information Between a Secure Module and Another Module,” to Stephen M.
`
`Curry, Donald W. Loomis, and Michael L. Bolan. A copy of the ’510 Patent is attached
`
`hereto as Exhibit A.
`
`9.
`
`On September 7, 1999, the United States Patent and Trademark Office duly
`
`and legally issued U.S. Patent No. 5,949,880 (“the ’880 Patent”), entitled “Transfer of
`
`In accordance with Federal Rule of Civil Procedure 13, Maxim brings these
`2
`compulsory counterclaims. Nonetheless, as stated above in footnote 1, Maxim believes
`that the Eastern District of Texas is a proper venue for all pretrial proceedings, and
`nothing in Maxim’s counterclaims should be construed otherwise.
`
`Page 6 of 15
`
`
`
`Valuable Information Between a Secure Module and Another Module,” to Stephen M.
`
`Curry, Donald W. Loomis, and Michael L. Bolan. A copy of the ’880 Patent is attached
`
`hereto as Exhibit B.
`
`10.
`
`On August 15, 2000, the United States Patent and Trademark Office duly
`
`and legally issued U.S. Patent No. 6,105,013 (“the ’013 Patent”), entitled “Method,
`
`Apparatus, System, and Firmware for Secure Transactions,” to Stephen M. Curry, Donald
`
`W. Loomis, and Christopher W. Fox. A copy of the ’013 Patent is attached hereto as
`
`Exhibit C.
`
`11.
`
`On May 22, 2001, the United States Patent and Trademark Office duly and
`
`legally issued U.S. Patent No. 6,237,095 (“the ’095 Patent”), entitled “Apparatus for
`
`Transfer of Secure Information Between a Data Carrying Module and an Electronic
`
`Device,” to Stephen M. Curry, Donald W. Loomis, and Christopher W. Fox. A copy of the
`
`’095 Patent is attached hereto as Exhibit D.
`
`12.
`
`Maxim is the owner of the ’510, ’880, ’013, and ’095 Patents (collectively,
`
`the “Asserted Patents”).
`
`COUNT I
`
`(Infringement of the ’510 Patent)
`
`13.
`
`Maxim incorporates and realleges paragraphs 1-12.
`
`14.
`
`PNC directly infringes one or more claims of the ’5l0 Patent (literally or
`
`under the doctrine of equivalents) by making, using, offering to sell, and/or selling
`
`products, devices, systems, and/or components of systems which embody the patented
`
`invention, including the PNC mobile banking software application for iPhone, iPod Touch,
`
`iPad, Android devices, and/or Windows Mobile devices.
`
`Infringement arises from the use
`
`of such application to communicate with systems operated by or on behalf of PNC.
`
`Page 7 of 15
`
`
`
`15.
`
`PNC induces its customers and other third parties to infringe one or more
`
`claims of the ’510 Patent (literally or under the doctrine of equivalents) at
`
`least by
`
`providing the PNC mobile banking software application for iPhone, iPod Touch,
`
`iPad,
`
`Android devices, and/or Windows Mobile devices, and instructions to use this application
`
`to customers. Customers and other third parties infringe by using such application to
`
`communicate with systems operated by or on behalf of PNC. PNC knew and/or was
`
`willfully blind that the acts it induced constituted patent infringement.
`
`16.
`
`PNC contributes to the infringement of the ’510 patent by selling, offering
`
`to sell, importing, and/or supplying components of the claimed subject matter of the ’5l0
`
`patent, including providing the PNC mobile banking software application for iPhone, iPod
`
`Touch,
`
`iPad, Android devices, and/or Windows Mobile devices to customers. This
`
`application is especially made and/or especially adapted for use in infringing the ’510
`
`patent and is not a staple article or commodity of commerce suitable for substantial non-
`
`infringing use.
`
`17.
`
`PNC had notice of the ’510 Patent by no later than about December 2, 2011.
`
`18.
`
`PNC has willfully infringed the ’5l0 Patent.
`
`19.
`
`PNC has committed these acts of infringement within the United States.
`
`20.
`
`PNC has committed these acts of infringement without
`
`license or
`
`authorization.
`
`21.
`
`Maxim has suffered damages as a result of PNC’s infringement of the ’5l0
`
`Patent.
`
`In addition, Maxim will continue to suffer severe and irreparable harm unless this
`
`Court
`
`issues a permanent
`
`injunction prohibiting PNC,
`
`its agents, servants, employees,
`
`Page 8 of 15
`
`
`
`representatives, and all others acting in active concert therewith from infringing the ’5l0
`
`Patent.
`
`COUNT II
`
`(Infringement of the ’880 Patent)
`
`22.
`
`Maxim incorporates and realleges paragraphs 1- 21.
`
`23.
`
`PNC directly infringes one or more claims of the ’880 Patent (literally or
`
`under the doctrine of equivalents) by using applications which embody the patented
`
`invention, including the PNC mobile banking software application for iPhone, iPod Touch,
`
`iPad, Android devices, and/or Windows Mobile devices.
`
`Infringement arises from the use
`
`of such application to communicate with systems operated by or on behalf of PNC.
`
`Infringement is either by PNC alone and/or in concert with customers or other third parties
`
`according to a common scheme or under the direction or control of PNC.
`
`24.
`
`PNC induces its customers and other third parties to infringe one or more
`
`claims of the ’880 Patent (literally or under the doctrine of equivalents) at
`
`least by
`
`providing the PNC mobile banking software application for iPhone, iPod Touch,
`
`iPad,
`
`Android devices, and/or Windows Mobile devices, and instructions to use this application
`
`to customers. Customers and other third parties infringe by using such application to
`
`communicate with systems operated by or on behalf of PNC. PNC knew and/or was
`
`willfully blind that the acts it induced constituted patent infringement.
`
`25.
`
`PNC contributes to the infringement of the ’880 patent by selling, offering
`
`to sell, importing, and/or supplying components of the claimed subject matter of the ’880
`
`patent, including providing the PNC mobile banking software application for iPhone, iPod
`
`Touch,
`
`iPad, Android devices, and/or Windows Mobile devices to customers.
`
`This
`
`application is especially made and/or especially adapted for use in infringing the ’880
`
`Page 9 of 15
`
`
`
`patent and is not a staple article or commodity of commerce suitable for substantial non-
`
`infringing use.
`
`26.
`
`PNC had notice of the ’880 Patent by no later than about December 2, 2011.
`
`27.
`
`PNC has willfully infringed the ’880 Patent.
`
`28.
`
`PNC has committed these acts of infringement within the United States.
`
`29.
`
`PNC has committed these acts of infringement without
`
`license or
`
`authorization.
`
`30.
`
`Maxim has suffered damages as a result of PNC’s infiingement of the ’880
`
`Patent.
`
`In addition, Maxim will continue to suffer severe and irreparable harm unless this
`
`Court issues a permanent injunction prohibiting PNC,
`
`its agents, servants, employees,
`
`representatives, and all others acting in active concert therewith from infringing the ’880
`
`Patent.
`
`COUNT III
`
`(Infringement of the ’013 Patent)
`
`31.
`
`Maxim incorporates and realleges paragraphs 1- 30.
`
`32.
`
`PNC directly infringes one or more claims of the ’013 Patent (literally or
`
`under the doctrine of equivalents) by making, using, offering to sell, and/or selling
`
`products, devices, systems, and/or components of systems which embody the patented
`
`invention, including the PNC mobile banking software application for iPhone, iPod Touch,
`
`iPad, Android devices, and/or Windows Mobile devices.
`
`Infringement arises when such
`
`application is combined with a mobile device and/or from the use of such application to
`
`communicate with systems operated by or on behalf of PNC.
`
`33.
`
`PNC induces its customers and other third parties to infringe one or more
`
`claims of the ’013 Patent (literally or under the doctrine of equivalents) at
`
`least by
`
`Page 10 of 15
`
`10
`
`
`
`providing the PNC mobile banking sofiware application for iPhone, iPod Touch,
`
`iPad,
`
`Android devices, and/or Windows Mobile devices, and instructions to use this application
`
`to customers. Customers and other third parties infringe by combining such application
`
`with a mobile device and/or using such application to communicate with systems operated
`
`by or on behalf of PNC. PNC knew and/or was willfully blind that the acts it induced
`
`constituted patent infringement.
`
`34.
`
`PNC contributes to the infringement of the ’013 patent by selling, offering
`
`to sell, importing, and/or supplying components of the claimed subject matter of the ’013
`
`patent, including providing the PNC mobile banking software application for iPhone, iPod
`
`Touch,
`
`iPad, Android devices, and/or Windows Mobile devices to customers.
`
`This
`
`application is especially made and/or especially adapted for use in infringing the ’0l3
`
`patent and is not a staple article or commodity of commerce suitable for substantial
`
`noninfringing use.
`
`35.
`
`PNC had notice of the ’013 Patent by no later than about December 2, 2011.
`
`36.
`
`PNC has willfully infringed the ’O13 Patent.
`
`37.
`
`PNC has committed these acts of infringement within the United States.
`
`38.
`
`PNC has committed these acts of infringement without
`
`license or
`
`authorization.
`
`39.
`
`Maxim has suffered damages as a result of PNC’s infringement of the ’013
`
`Patent.
`
`In addition, Maxim will continue to suffer severe and irreparable harm unless this
`
`Court
`
`issues a permanent
`
`injunction prohibiting PNC,
`
`its agents, servants, employees,
`
`representatives, and all others acting in active concert therewith from infringing the ’013
`
`Patent.
`
`Page 11 of 15
`
`11
`
`
`
`COUNT IV
`
`(Infringement of the ’095 Patent)
`
`40.
`
`Maxim incorporates and realleges paragraphs 1- 39.
`
`41.
`
`PNC directly infringes one or more claims of the ’095 Patent (literally or
`
`under the doctrine of equivalents) by making, using, offering to sell, and/or selling
`
`products, devices, systems, and/or components of systems which embody the patented
`
`invention, including the PNC mobile banking software application for iPhone, iPod Touch,
`
`iPad, Android devices, and/or Windows Mobile devices.
`
`Infringement arises when such
`
`application is combined with a mobile device and/or from the use of such application to
`
`communicate with systems operated by or on behalf of PNC.
`
`42.
`
`PNC induces its customers and other third parties to infringe one or more
`
`claims of the ’095 Patent (literally or under the doctrine of equivalents) at
`
`least by
`
`providing the PNC mobile banking software application for iPhone, iPod Touch,
`
`iPad,
`
`Android devices, and/or Windows Mobile devices, and instructions to use this application
`
`to customers. Customers and other third parties infringe by combining such application
`
`with a mobile device and/or using such application to communicate with systems operated
`
`by or on behalf of PNC. PNC knew and/or was willfully blind that the acts it induced
`
`constituted patent infringement.
`
`43.
`
`PNC contributes to the infringement of the ’095 patent by selling, offering
`
`to sell, importing, and/or supplying components of the claimed subject matter of the ’095
`
`patent, including providing the PNC mobile banking software application for iPhone, iPod
`
`Touch,
`
`iPad, Android devices, and/or Windows Mobile devices to customers. This
`
`application is especially made and/or especially adapted for use in infringing the ’095
`
`Page 12 of 15
`
`12
`
`
`
`patent and is not a staple article or commodity of commerce suitable for substantial non-
`
`infringing use.
`
`44.
`
`45.
`
`46.
`
`47.
`
`authorization.
`
`PNC had notice of the ’095 Patent by no later than about December 2, 2011.
`
`PNC has willfully infringed the ’095 Patent.
`
`PNC has committed these acts of infringement within the United States.
`
`PNC has committed these acts of infringement without
`
`license or
`
`48.
`
`Maxim has suffered damages as a result of PNC’s infringement of the ’095
`
`Patent.
`
`In addition, Maxim will continue to suffer severe and irreparable harm unless this
`
`Court
`
`issues a permanent injunction prohibiting PNC,
`
`its agents, servants, employees,
`
`representatives, and all others acting in active concert therewith from infringing the ’095
`
`Patent.
`
`PRAYER FOR RELIEF
`
`For the above reasons, Maxim respectfully requests that
`
`this Court grant
`
`the
`
`following relief in favor of Maxim and against PNC:
`
`(a)
`
`A judgment in favor of Maxim that PNC has infringed (either literally or
`
`under the doctrine of equivalents) one or more claims of the Asserted
`
`Patents;
`
`(b)
`
`A permanent injunction enjoining PNC and its officers, directors, agents,
`
`servants, affiliates, employees, divisions, branches, subsidiaries, parents,
`
`and all others acting in active concert or participation with PNC, from
`
`infringing the Asserted Patents;
`
`(C)
`
`A judgment and order requiring PNC to pay Maxim its damages, costs,
`
`Page 13 of 15
`
`13
`
`
`
`expenses,
`
`and pre-judgment
`
`and post-judgment
`
`interest
`
`for PNC’s
`
`infringement of the Asserted Patents;
`
`(d)
`
`An award of treble damages for PNC’s willful infringement of the Asserted
`
`Patents;
`
`(e)
`
`A judgment and order finding that this is an exceptional case within the
`
`meaning of 35 U.S.C. § 285 and awarding Maxim its reasonable attorney
`
`fees; and
`
`(0
`
`Any and all such other relief as the Court deems just and proper.
`
`DEMAND FOR JURY TRIAL
`
`Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Counterclaimant
`
`Maxim demands a trial by jury of this action.
`
`Respectfully submitted,
`
`MAXIM INTEGRATED PRODUCTS, INC.
`
`By:
`
`/s/ Leland P. Schcrmer
`Leland P. Schermer, Esquire
`Pa. ID No. 47283
`
`Bryan A. Loose, Esquire
`Pa. ID No. 201385
`
`LELAND SCHERMER & ASSOCIATES, PC
`
`Henry W. Oliver Building
`535 Smithfield Street, Third Floor
`Pittsburgh, PA 15222
`Phone: (412) 642-5000
`Fax:
`(412) 642-5010
`Email:
`lschermer@,schermerlaw.com
`
`Attorneys for Defendant and Counterclaim Plaintiff,
`Maxim Integrated Products, Inc.
`
`JURY TRIAL DEMANDED
`
`Dated: June 6, 2012
`
`Page 14 of 15
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that I caused a true and correct copy of the foregoing MAXIM
`
`INTEGRATED
`
`PRODUCTS,
`
`INC.’S
`
`ANSWER
`
`TO
`
`COMPLAINT
`
`FOR
`
`DECLARATORY JUDGMENT AND COUNTERCLAIMS to be served via the Western
`
`District of Pennsylvania’s ECF filing system this 6th day of June 2012, on counsel for
`
`Plaintiffs as follows:
`
`Alysa N. Youngson, Esquire
`Finnegan Henderson Farabow Garrett & Dunner, LLP
`Two Freedom Square
`11955 Freedom Drive
`
`Reston, VA 20190-5673
`al sa. oun son
`finne an.com
`
`Lionel M. Lavenue, Esquire
`Finnegan Henderson Farabow Garrett & Dunner, LLP
`Two Freedom Square
`11955 Freedom Drive
`
`Reston, VA 20 1 90-5 673
`lionel.lavenue@finnegan.com
`
`Scott R. Leah, Esquire
`Tucker Arensberg
`1500 One PPG Place
`
`Pittsburgh, PA 15222
`sleah@tuckerlaw.com
`
`/s/Leland P. Schermer
`Leland P. Schermer
`
`Page 15 of 15
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