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`HLEB SE?A TEL?
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`SONY EXHIBIT 1002 - 0251
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`SONY EXHIBIT 1002 - 0251
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`UNETEB STATES ll\lTERNATlGNAL TRADE CGl‘vllldlSlGl‘tl
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`W’ASHfNGTGl‘=l, RC.
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`Before the Honorable Thomas B. Fender
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`Adnilnlstrattve Law judge
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`In the Matter of
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`j V
`j _“_
`_ “Y
`1 H
`Clglli l. Alht W lRl:.L.l;;E>:a‘ .l.‘ll:-._/-‘tl)€=lf.-
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`l. 5‘
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`InvestigationNo.337—TA—943
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`
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`Respondents BhieAiit ‘Wireless, lnc. and BlneA.nt ‘Wi.re.le.ss Pty. Ltd. (collectively,
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`“Bl,tt6Ant”:} hereby respond to the Cornplaint filed by 0ne—E—‘Way, lnc. (“Coniplainant” or
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`“One—E5Way”) on Deeeniber 8, 2014, in the above-captioned investigation and to the Notice of
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`lnvestigation issued by the United States lnternational Trade Conirnission (“the Con'irr1ission”) as
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`published in the Federal Register on January 13, 2015. (80 Fed. Reg.
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`l_,:':i63).
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`BlaeAnt denies that it has engaged in acts of unfair competition in violation of Section
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`337 by irnporting, selling for importation, and,/or selling after irnportation into the United States
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`any product that infringes literally and? or under the doctrine of equivalents, directly, indirectly,
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`by contribution andfor by inducement, any claim of U.S. Patent No. 7,865,258 (“the ’258
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`patent”) and United States Patent No. 8, l3 l,39l_ {the 391 patent) {e.oll.ecti.ve.ly “patents-in—snit”).
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`l3lneArit denies that the claims of the ’258 and ‘E391 patents are valid and enforceable.
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`Except as specifically adrnitted herein, Bl’neAn1‘ denies all of the allegations of the
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`Cornplaint.
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`l3l.neAnt has not had sufficient time and opportunity to collec.t and review all of the
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`l,flfO1'D]£ilLl()U, that may be relevant and necessary to respond to the matters raised in One—l3—‘s7Vay"s
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`Complaint. To the extent that any allegations of the Complaint refer to or rely upon information
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`not previously supplied to BhieArit, Blne.Ant is wit.ho11t information stiffi.cie.rit to admit or deny
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`such allegations, and therefore denies the sanie.
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`l\xloreo\/er, BlueArit also reserves the right to
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`take fnrther positions and raise additional defenses as rnay become apparent as a result. of
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`additional. inforrnation discovered subsequent to filing this Response.
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`SONY EXHIBIT 1002 - 0252
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`SONY EXHIBIT 1002 - 0252
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`The numbered Paragraphs herein correspond to and respond to the numbered Paragraphs
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`set forth in the Complaint.
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`E.
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`ENTRODUCTEQNE
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`l.
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`Bluefitnt admits that On.e-E—VVay requested that the United States lnternational
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`Trade Commission commence an investigation pursuant to Section 337 of the Tariff Act of 1930,
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`as amended, 19 U.S.C. §l337, and that One—E-—W'ay seeks a remedy for what it contends is the
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`unlawful importation or articles covered by the patents—in—suit. Bl.ue.Ant denies that it has
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`engaged in acts of unfair cornpctition in violation of Section 337 by importing, selling for
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`importation, and! or selling within the United States after importation any articles covered by the
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`patents—in—suit. Bluefitnt denies that the patents—in—suit are in.frin.ged, valid or enforceable.
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`Blfl-f_’.AI11‘ lacks sufficient knowledge or information on which to admit or deny t.he remaining
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`allegations of Paragraph l and, on that basis, denies them. Except as expressly admitted,
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`Bluefitnt denies each and every allegation of Paragraph l of the Complaint.
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`2.
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`Blfl-f_’.AI11‘ admits that. documents purporting t.o be certified copies of the patents—in—
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`su.it are attached to the Complaint as Exliihits 1 and 2, but lacks ltnowledge or information
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`sufficient to form a helief regarding l:";—One—§Vay’s allegation that Exhibits l and '2 are true and
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`correct copies of the patents—in—suit. BlueAnt admits that documents purporting to he cert.ificd
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`copies of assignments of the patents—in—suit are attached to the complaint as EXl1ll‘tll'S 3 and 4, hut
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`lacls:_s knowledge or information. sufficient to form a helief regarding E.—One-§Vay’s allegation that
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`l3xhibi’ts 3 and 4 are true and correct. copies of assignrnents of the patents—in—suit. Bluezlint
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`denies that it unlawfully imports, sells for importation, andf or sells after importation articles that
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`infringe any claim of the patents—in-suit, directly or indirectly. Bl.ue.Ant denies that it infringes
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`(directly or indirectly) claims 3, 4, 8,
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`ll} and ll of the ’258 patent.. BlueAnt denies that. it
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`infringes {directly or indirectly) claims 3 and 4 of the 391 patent. To the extent such allegations
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`are contained in Paragraph 2, l3lueAnt denies the patents—in—suit are valid or enforceable. Except
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`1 For purposes of clarity and ease of reference, Blue.A.n.t responds to the Complaint using the
`same format and tit.les used by One-l3—W'ay. Nonet.heless, the use of this format and these t.itles
`should. not he construed as an admission on BlueAnt.’s part to any of the facts and? or allegations
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`SONY EXHIBIT 1002 - 0253
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`as expressly admitted, Blueritnt denies each and every allegation of Paragraph 2 of the
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`Complaint.
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`3.
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`BlueAnt admits that One—E—W'ay narned Sony Corporation, Sony Corporation of
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`America, Sony Electronics, lnc., Sennheiser Electronic Gnfihll & Co. KG, Sennheiser El.€Cl.1"()1‘JlC
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`Corporation, l3ltieAnt ‘Wireless Pty, Ltd, BlueAnt Vlfireless, lnc., Creative Technology Ltd,
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`Creative Labs, lnc., Beats Electronics, LLC, Beats Electronics lnternational Ltd., lawhoiie, lne.,
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`and
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`Neteorn S which does business as Jabra (collectively, “Respondents”) as Respondents
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`in this lnvestigation. BlueAnt denies that it has engaged in unfair acts in violation of Section 337
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`thorough the unlawful importation, sale for irnportation, and for sale after importation of certain
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`wireless audio devices covered by one or more clairns of the paten.ts—in—suit. To the extent such
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`allegations are contained in Paragraph 3, BlllCAflf denies the patents-in-suit are valid or
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`enforceable. BltieAnt lacks sufficient lrnowledge of information on which to admit or deny the
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`remaining allegations of Paragraph 3 and, on that basis, denies thern. Except as expressly
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`admitted, BlueAnt denies each and every allegation of Paragraph 3 ofthe Coinplaint.
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`4.
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`5.
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`On inforrnation and belief, BlueAnt d.enies the allegations of Paragraph 4.
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`Blneritnt admits that On.e-E—VVay seeks a limited exclusion order and a cease and
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`desist. order, but denies that C!ne—E.-‘Way is entitled to any such relief. BlueAnt denies the
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`remaining allegations of Paragraph 5.
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`ll ..
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`6.
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`Blfl-f.’.AI11‘ lacks sufficient lenowledge or information on which to admit or deny the
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`allegations of Paragraph 6 and, on that basis, denies thein.
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`Ell.
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`RESPONDENTS
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`Sonar Son ’ Anieriea and Sonv E-leetr-nnles
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`7.
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`The allegations of Paragraph '7’ are not directed to Blireiitnt and therefore no
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`answer is required. To the extent an answer is required, l3lueAnt lacks snfl’ici.en.t knowledge or
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`inforrnation on which to admit or deny such allegations and, on that basis, denies them.
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`8.
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`The allegations of Paragraph 8 are not directed to BlueAnt and therefore no
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`answer is required. To the extent an answer is required, BlueAnt lacks sufficient l<;_n_owledge or
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`information on which t.o admit or deny such allegations and, on that basis, denies thern.
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`SONY EXHIBIT 1002 - 0254
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`SONY EXHIBIT 1002 - 0254
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`9.
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`The allegations of Paragraph 9 are not directed to l3lueAnt and thereliore no
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`answer is required, To the extent an answer is required, BlueAnt laelis sufficient lenowledge or
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`information on which to admit or deny such allegations and, on that basis, denies thein.
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`ll].
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`The allegations of Paragraph l0 are not directed to BlueAnt and therefore no
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`answer is required. To the extent an answer is required, BlueAnt lacks sufficient. knowledge or
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`inforrnation on which to admit or deny such allegations and, on that basis, denies theni.
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`ll.
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`The allegations of Paragraph 11 are not directed to Bluerfitnt and therefore no
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`answer is required. To the extent an answer is required, l3lueAnt lacks snlfieient knowledge or
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`inl’orrnation on which to admit or deny such allegations and, on that basis, denies tl’t€1'l,“l.
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`l2.
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`The allegations of Paragraph l2 are not directed to BlueAnt and theretc_ire no
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`answer is required. To the extent an answer is required, BlueAnt lacl<:s sufficient linowledge or
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`I-.l”1l“Oit'?t')Tl£ilLl()t‘l, on which to adniit or deny such allegations and, on that basis, denies thern.
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`l3.
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`The allegations of Paragraph 13 are not directed to Bluerfitnt and therefore no
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`answer is required. To the extent an answer is required, l3lueAnt lacks snlfieient knowledge or
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`inl’orrnation on which to admit or deny such allegations and, on that basis, denies then].
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`l4.
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`Blnerfxnt Wireless Pty. Ltd. adrnits that it is organized under the laws of Australia.
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`Except
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`expressly admitted, BlueAnt denies each and every allegation ol‘ Paragraph 14 of the
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`Complaint.
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`l5.
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`BlueAnt ‘Wireless, lne. adrnits it is a subsidiary ol BlueAnt ‘Wireless Pty., Ltd, that
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`it is a California Corporation and that it had, at one time, a place ol business at l25 §7Vacl(er
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`Drive, Suite 300, in Chicago, Illinois 6()6tl6. BlneAnt. ‘Wireless, lne. denies that it currently has a
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`place of business at that location. Except as expressly adrnitted, BlueAnt denies each and every
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`allegation oi‘ Paragraph l5 of the Complaint.
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`l6.
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`The allegations of Paragraph l6 are not directed to BlueAnt and therefore no
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`answer is required. To the extent an answer is required, BlueAnt laclis sul’li.cient lmowledge or
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`information on which to admit or deny such allegations and, on that basis, denies thern.
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`SONY EXHIBIT 1002 - 0255
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`SONY EXHIBIT 1002 - 0255
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`l7’.
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`The allegations of Paragraph ’l,’,7' are not directed to Bl.ueAnt and therefore no
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`answer is required. To the extent an answer is required, BlueAnt‘ laelrs sntTieie.nt knowledge or
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`inforrnation on which to adniit or deny such allegations and, on that basis, denies thern.
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`lb’.
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`The allegations of Paragraph l8 are not directed to BlueAnt and therefore no
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`answer is required. To the extent an answer is required, BlueAnt lacks sufficient. knowledge or
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`inforrnation on which to admit or deny such allegations and, on that basis, denies thern.
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`l9.
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`The allegations of Paragraph 19 are not directed to Bill‘?/.LAl._I1t and therefore no
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`answer is required. To the extent an answer is required, l3lueAnt lacks sufficient knowledge or
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`inl’orrnation on which to adrnit or deny such allegations and, on that basis, denies ll’t€1'l,“t.
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`2.0.
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`The allegations of Paragraph 20 are not directed to BlueAnt and therefore no
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`answer is required- To the extent an answer is required, BlueAnt lacks sufficient knowledge or
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`inlornfration. on which to adniit or deny such allegations and, on that basis, denies them.
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`21.
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`The allegations of Paragraph 21 are not directed to Bill‘?/.LAl._I1t and therefore no
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`answer is required. To the extent an answer is required, l3lueAnt lacks sufficient knowledge or
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`inl’orrn,ation on which to admit or deny such allegations and, on that basis, denies then].
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`5 awbune
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`22.
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`The allegations of Paragraph 22 are not directed to Blu.eAnt and therefore no
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`answer is required. To the extent an answer is required, l3lueAnt lacks sufl’ici.ent knowledge or
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`inforrnation on which to admit or deny such allegations and, on that basis, denies theni.
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`slabra
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`23.
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`The allegations of Paragraph 23 are not directed to BlueAnt and therefore no
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`answer is required. To the extent an answer is required, BlueAnt lacks sufficient. knowledge or
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`inforrnation on which to admit or deny such allegations and, on that basis, denies thern.
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`EV.
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`0NE~E—§‘rVA.7r”S ALLEGATTEENS OF TECEENGLGGEES AN}? PRQDUCTS AT
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`ESSUE
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`24.
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`To the extent the allegations of Paragraph 24 are not directed at BlueAnt, no
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`answer is required, but to the extent an answer is required, Eluezlint lacks sufficient knowledge or
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`information on which to admit or deny any such allegations and, on that basis, denies theni.
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`SONY EXHIBIT 1002 - 0256
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`SONY EXHIBIT 1002 - 0256
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`Blnefitnt denies that any of its products infringe or have infringed any valid and enforceable
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`Asserted Claim of the Asseited Patents. Except as expressly admitted. BlueAnt denies each and
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`every allegation of Paragraph 24 of the Complaint.
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`V-
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`2.5.
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`The allegations of Paragraph 25 are not directed to BlueAnt and therefore no
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`answer is required. To the extent an answer is required, BlneAnt admits that the prosecution
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`history on its face supports C=n.e—E—‘Way’s contention that the ’39l Patents issues frorn U .8.
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`Patent Application No.
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`l2.r‘94l_l,747, which appears t.o be a continuation application of U Patent
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`Application No. l2f570,343, which issued as the ’258 Patent. The public record on its face
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`shows that both patents claim priority to U .52‘. Patent Application No. l0/tl‘27,39l, filed December
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`21, 20t'_ll but BlneAnt lacks sufficient knowledge or information on which to admit. or deny One-
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`E-VVay’s right to the alleged priority date and, on that basis. denies that allegation.
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`l3lueAnt
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`l_acls:_s sufficient knowledge or information on which to admit or deny the remaining allegations of
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`Paragraph 25 and, on that basis, denies them.
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`l3ace.pt as expressly atlniitted, Bltiezlint denies each
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`allegation of Paragraph 25 of the Complaint.
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`A.
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`The ’253 Patent
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`lde
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`26.
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`ion of the Patent an
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`.3 ed Qwners
`Bliieriint admits that the ’258 patent is entitled. “‘Wireless Digital Audio Jfiystein.”
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`Blnefitnt admits that the ’258 patent states on its face that it issued on January 4, 20}. l. Blnefitnt
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`admits t.he °2:38 patent states on its face t.hat the inventor is C. Earl Wcolforlt, but BlneAnt lacks
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`sufficient knowledge or information on which to admit or deny that C. Earl ‘Wooll"oi‘l<: is the true
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`and sole inventor and, on that basis, denies that allegation. BlaeAn.t lacks sufficient lmowledge
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`or information on which to admit or deny the remaining allegations of Paragraph 2:3} and, on that
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`basis, denies them.
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`27.
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`l3lueAnt .‘:it.ll’i‘ll.l'.S that what purport to he certified copies of the of the prosecution
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`history of the “.258 patent and copies of reference tlocnnients mentioned in the prosecution
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`history are included as Appendices A and B to the Complaint. BlneAnt lacks sufficient
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`lgnowledge or inforrnation on which to admit or deny the remaining allegations of Paragraph 27
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`and, on that. basis, denies them.
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`SONY EXHIBIT 1002 - 0257
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`SONY EXHIBIT 1002 - 0257
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`One-E-=W’a ’s Non-Techriieal ljlescrition of the Patented lrirention
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`28.
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`Bl’tt-EAI11‘ disagrees with One—E§Way’s characterization of the technology, and
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`therefore denies the allegations of Paragraph 28. To the extent Paragraph 28 Yflftlit-ES allegations
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`regarding the alleged inVen_tion and the scope of the elairns, BlueAnt denies such allegations.
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`BltreAnt’s responses are not int.ended to interpret the meaning or scope of the claims in the “E258
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`patent. BlueAnt denies the remaining allegations of Paragraph 28.
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`29.
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`The allegations of Paragraph 29 are not directed to Bl.ueAnt and therefore no
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`answer is required, To the extent an answer is required, BlueAnt disagrees with One—E3Way’s
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`Cl1Et1‘ttCl.£'f1‘lZi:tl.l011 of the technology, and therefore denies the allegations of Paragraph 29. To the
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`extent Paragraph 29 makes allegations regarding the alleged invention and the scope of the
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`claims, BlueAr1t denies such allegations. Bluejitnt’ s responses are not intended to interpret the
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`rneaning or scope of the claims in the "258 patent.
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`l3lueAnt denies the remaining allegations of
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`Paragraph 29.
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`B.
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`The ‘$91 Patent
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`ldeiitificatioii of the Patent arid Alle ed Qwrierslii h 7 Dire-E»'Wa ‘
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`30.
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`Blueritnt denies that the ’39l patent is entitled °‘loVi.reless Digital Audio Systeni.”
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`Bl’tt-EAI11‘ admits that. the ’39.l patent states on its face that it. issued on March 6, 2.012 and appears
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`to he a continuation of the earlier patent application that issued as the ’258 patent. Blu.eAiit
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`admits the ’39l patent states on its face that the inventor is C. Earl lVooll’orl<, but l3lueAnt lacks
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`sufficient. ltnowledge or information on which to admit or deny that. C. Earl Vfoolforlt is the true
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`and sole inventor and, on that basis, denies that allegation.
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`l3lueAnt lacks sufficient lenowletlge
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`or information on which to admit or deny the remaining allegations of Paragraph 30 and, on that
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`hasis, denies them.
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`31.
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`Blue-.Ant admits that What purport to be certified copies of the of the prosecution
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`history of the ’39l patent and copies of reference documents rnentioried in the prosecution
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`history are included as Appendices C and D to the Cornplain’t.
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`l3lueAnt lael~:s sufficient
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`knowledge or information on which to admit or deny the remaining allegations of Paragraph Bl
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`and, on that hasis, denies them.
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`SONY EXHIBIT 1002 - 0258
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`SONY EXHIBIT 1002 - 0258
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`One-E-=W’a ’s l\'ori-Technical ljleserition of the Patented lnrention
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`32.
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`Bl’tt-EAI11‘ disagrees with One—E—‘Way’s characterization of the technology, and
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`therefore denies the allegations of Paragraph 32. To the extent Paragraph 32 inahes allegations
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`regarding the alleged invention and the scope of the elairns, BlueAnt denies such allegatioiis.
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`BlueAnt’s responses are not intended to interpret the meaning or scope of the claims in the 1391
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`patent.
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`l3lu.eAnt denies the reinaining allegations of Paragraph 32.
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`33.
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`The allegations of Paragraph 33 are not directed to Bl.ueAnt and therefore no
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`answer is required. To the extent an answer is require.d, BlueAnt disagrees with One—E3Way’s
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`characterizjation of the technology, and therefore denies the allegations of Paragraph 33. To the
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`extent Paragraph 33 makes allegations regarding the alleged invention and the scope of the
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`claims, BlueAnt denies such allegations. BlueAnt’ s responses are not intended to interpret the
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`rneaning or scope of the elainis in the ’39l patent.
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`l3lueAnt denies the remaining allegations of
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`Paragraph 33.
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`VI.
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`ONE-E-Vlrfl-'-‘tY’S ALLl3GATlQl‘«lS OF UNFAIR ACTS BY RESPONDENTS
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`34.
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`The allegations of Paragraph 34 are not directed to l3lueAn,t and therefore no
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`answer is required. To the extent an answer is required, l3lueAnt lacks sufficient. knowledge or
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`inforination on which to admit or deny such allegations and, on that hasis, denies theni.
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`The allegations of Paragraph 35 are not directed to Bl.ueAnt and therefore no
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`answer is required. To the extent an answer is require.d, BlueAnt laelrs sufficient lénowledge or
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`inforniation on which to adnnt or deny such allegations and, on that basis. denies thein.
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`36.
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`The allegations of Paragraph
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`are not directed to l3lueAn,t and therefore no
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`answer is required. To the extent an answer is required, l3lueAnt lacks sufficient. knowledge or
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`inforination on which to admit or deny such allegations and, on that hasis, denies theni.
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`37.
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`The allegations of Paragraph 37 are not directed to Bl.ueAnt and therefore no
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`answer is required. To the extent an answer is require.d, BlueAnt laelrs sufficient lénowledge or
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`inforniation on which to adnnt or deny such allegations and, on that basis. denies thein.
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`SONY EXHIBIT 1002 - 0259
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`SONY EXHIBIT 1002 - 0259
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`38.
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`The allegations of Paragraph 38 are not directed to Bl.ueAnt and therefore no
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`answer is required. To the ext.ent an answer is required, BlueAnt lacks sufficient knowledge or
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`information on which to adniit or deny such allegations and, on that basis, denies them.
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`39.
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`The al,legati.oris of Paragraph 39 are not directed to BlueAn.t and therefore no
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`answer is required. To the extent an answer is required, BlueAnt lacks sufficient. knowledge or
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`information on which to admit or deny such allegations and, on that basis, denies then].
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`40.
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`The allegations of Paragraph 40 are not directed to Bl.ueAnt and therefore no
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`answer is required. To the ext.ent an answer is required, BlueAnt lacks sufficient knowledge or
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`information on which to adniit or deny such allegations and, on that basis, denies them.
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`B.
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`€}n.e—l?,'-‘Wav’s A,l_leatlans For Sennhelser and Sennlielser America
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`41.
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`The allegations of Paragraph 4l are not directed to BlueAnt and therefore no
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`answer is required. To the extent an answer is required, BlueAnt lacks sufficient knowledge. or
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`information. on which to admit or deny such allegations and, on that basis, denies them.
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`42.
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`The allegations of Paragraph 42 are not directed to Bluei/lint and therefore no
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`answer is required. To the extent an answer is required, l3lueAnt lacks sufficient knowledge or
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`inform,ati_on on which to admit or deny such allegations and, on that basis, denies then].
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`43.
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`The allegations of Paragraph 43 are not directed to BlueAnt and therefore no
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`answer is required. To the extent an answer is required, BlueAnt lacks sufficient knowledge. or
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`information. on which to admit or deny such allegations and, on that basis, denies them.
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`The allegations of Paragraph 44 are not directed to Bluei/lint and therefore no
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`answer is required. To the extent an answer is required, l3lueAnt lacks sufficient knowledge or
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`inform,ati_on on which to admit or deny such allegations and, on that basis, denies then].
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`45.
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`The allegations of Paragraph 45 are not directed to BlueAnt and therefore no
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`answer is required. To the extent an answer is required, BlueAnt lacks sufficient knowledge. or
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`information. on which to admit or deny such allegations and, on that basis, denies them.
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`46.
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`The allegations of Paragraph 46 are not directed to Bluei/lint and therefore no
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`answer is required. To the extent an answer is required, l3lueAnt lacks sufficient knowledge or
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`inform,ati_on on which to admit or deny such allegations and, on that basis, denies then].
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`SONY EXHIBIT 1002 - 0260
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`SONY EXHIBIT 1002 - 0260
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`47.
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`The allegations of Paragraph 47 are not directed to Bl.ueAnt and therefore no
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`answer is required. To the extent an answer is required, BlueAnt lacks sufficient lcnowledge or
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`information on which to admit or deny such allegations and, on that basis, denies them.
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`C.
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`{}n.e-E—'Wav’s A_l_leat_lons For Blucfitnt and Blueiin t-=US
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`48.
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`BlllCAfll denies that it rnanufactnres, rnarlcets, sells for iinportation, imports, and
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`for sells after importation into the United States products that infringe, either directly or
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`indirectly, any valid and enl‘orceabl_e A sserted Claim ol‘ the patents—in—suit. Bl.ue.Ant denies. the
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`remaining allegations of Paragraph 48.
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`49.
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`Blur-:Ant admits that Oiie—E.—W'ay has identified BlueAnt products sold under the
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`names Ribbon, PUl\/IP, Q2, Q3, Tl, Connect and Endure
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`Acc used Products, but denies that
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`any BlueAnt product infringes any valid and enforceable asserted claim of the patents-in-suit.
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`Blur-:Ant admits that Exhibit ll includes images of the Pump, Q3, Ribbon and Tl products.
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`Paragraph 49 contains legal argument for which no answer
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`required. Blueritnt denies any
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`remaining allegations of Paragraph 49.
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`50.
`
`Blur-:Ant admits that its products are manufactured, assembled and! or packaged.
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`outside the United States.
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`l3lueAnt admits that One—E—”Way has identified Bluefitnt products as
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`Accused Products, but denies that BlueAnt imports, sells for irnpcrtation, or sells alter
`
`importation any products that infringe any Valid and enforceable Asserted Claim of the patents-
`
`in—suit.
`
`l?3lueAnt l_ack_s sullicient knowledge or inliorrnation on which to admit or deny the
`
`remaining allegations of Paragraph 50 and, on that basis, denies them.
`
`51.
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`Blur-:Ant denies that it infringes, directly or indirectly, any valid and enforceable
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`claim of the ’39l patent. Blueritnt admits that Exhibit l2 to the Cornplaint contains a chart
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`purporting to cornpare claims 391 patent to BlueAnt accused products, but denies that such chart
`
`is accurate and denies the allegations in the chart. Blu.eAnt denies any remaining allegations of
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`Paragraph
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`52.
`
`BlneAnt denies that it infringes, directly or indirectly, any valid and enforceable
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`any claim of the ’258 and “B91 patents. BlueAnt admits that Exliibit l3 to the Complaint
`
`contains a chart purporting to compare claims of the patents—in—suit to the l3lueAnt accused
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`SONY EXHIBIT 1002 - 0261
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`SONY EXHIBIT 1002 - 0261
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`

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`products, but denies that such chart is accurate and denies the allegations in the chart.
`
`l3lueAnt
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`denies any remaining allegations of Paragraph 52.
`
`53.
`
`Paragraph 53 contains legal argurnent and conclusions; therefore, no answer is
`
`required. To the extent an answer is required, Bl ueAnt denies all allegations of Paragraph 53.
`
`54.
`
`Paragraph 54 contains legal argument and conclusions; therefore, no answer is
`
`required. To the extent an answer is required, BlueAnt denies all allegations of Paragraph 54.
`
`D.
`
`One—E~’Wa"s Alleations For Creative and Creative Lahs
`
`55.
`
`The allegations of Paragraph 55 are not direet.ed to Bluerltnt and therefore no
`
`answer is required. To the extent an answer is required, l3lueAnt lacks sufficient knowledge or
`
`inlorrnation on which to admit or deny such allegations and, on that hasis, denies thein.
`
`56.
`
`The allegations of Paragraph 56 are not directed to BlueAnt and therefore no
`
`answer is required- To the extent an answer is required, BlueAnt lacks sufficient knowledge or
`
`I-,l”1llO1'l')Tt£ilLl()t‘l, on which to udrnit or deny such allegations and, on that basis, denies them.
`
`57.
`
`The allegations of Paragraph 57 are not direet.ed to Bluerltnt and therefore no
`
`answer is required. To the extent an answer is required, l3lueAnt lacks sufficient knowledge or
`
`inforrnation on which to admit or deny such allegations and, on that basis, denies thein.
`
`58.
`
`The allegations of Paragraph 58 are not directed to BlueAnt and therefore no
`
`answer is required. To the extent an answer is required, BlueAnt lacks sufficient knowledge or
`
`I-,l”1llO1'l')Tt£ilLl()t‘l, on which to udrnit or deny such allegations and, on that basis, denies them.
`
`59.
`
`The allegations of Paragraph 59 are not direet.ed to Bluerltnt and therefore no
`
`answer is required. To the extent an answer is required, l3lueAnt lacks sufficient knowledge or
`
`inforrnation on which to admit or deny such allegations and, on that basis, denies thein.
`
`60.
`
`The allegations of Paragraph 60 are not directed to BlueAnt and therefore no
`
`answer is required- To the extent an answer is required, BlueAnt lacks sufficient l<:nowledge or
`
`I-,l”1llO1'l')Tt£ilLl()t‘l, on which to udrnit or deny such allegations and, on that basis, denies them.
`
`61.
`
`The allegations of Paragraph 61 are not direet.ed to Bluerltnt and therefore no
`
`answer is required. To the extent an answer is required, l3lueAnt lacks sufficient knowledge or
`
`inforrnation on which to admit or deny such allegations and, on that basis, denies thein.
`
`SONY EXHIBIT 1002 - 0262
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`SONY EXHIBIT 1002 - 0262
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`

`
`E.
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`One-E~’Wa"s Alleatlons For Beats and Beats Treland
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`
`62.
`
`The allegations of Paragraph 62 are not directed to Bluertnt and therefore no
`
`answer is required. To the extent an answer is required, l3lueAnt lacks sufficient knowledge or
`
`inforrnation on which to admit or deny such allegations and, on that basis, denies them.
`
`63.
`
`The allegations of Paragraph 63 are not directed to BlueAnt and therefore no
`
`answer is required. To the extent an answer is required, BlueAnt lacks sufficient knowledge or
`
`l,I1ft)tD]£itl()U, on which to adniit or deny such allegations and, on that basis, denies them.
`
`64.
`
`The allegations of Paragraph 64- are not directed to Bluertnt and therefore no
`
`answer is required. To the extent an answer is required, l3lueAnt lacks sufficient knowledge or
`
`inforrn,ati,on on which to adrnit or deny sueh allegations and, on that hasis, denies thern.
`
`65.
`
`The allegations of Paragraph 65 are not directed to BlueAnt and therefore no
`
`answer is required To the extent an answer is required, BlueAnt lacks sufficient knowledge or
`
`l,I1ft)tD]£itl()U, on which to adniit or deny such allegations and, on that basis, denies them.
`
`66.
`
`The allegations of Paragraph 66 are not directed to Bluertnt and therefore no
`
`answer is required. To the extent an answer is required, l3lueAnt lacks sufficient knowledge or
`
`inforrnation on which to admit or deny such allegations and, on that basis, denies them.
`
`67.
`
`The allegations of Paragraph 67 are not directed to BlueAnt and therefore no
`
`answer is required. To the extent an answer is required, BlueAnt lacks sufficient knowledge or
`
`l,I1ft)tD]£itl()U, on which to adniit or deny such allegations and, on that basis, denies them.
`
`68.
`
`The allegations of Paragraph 68 are not directed to Bluertnt and therefore no
`
`answer is required. To the extent an answer is required, l3lueAnt lacks sufficient knowledge or
`
`inforrnation on which to admit or deny such allegations and, on that basis, denies them.
`
`Fa
`
`
`
`
`
`69.
`
`The allegations of Paragraph 69 are not directed to BlueAnt and therefore no
`
`answer is required. To the extent an answer is required, l3lueAnt lacks sufficient knowledge or
`
`inforrnation on which to admit or deny such allegations and, on that basis, denies them.
`
`70.
`
`The allegations of Paragraph 70 are not directed to BlueAnt and therefore no
`
`answer is required. To the extent an answer is required, BlueAnt laclis sufficient knowledge or
`
`information on which to admit or deny such allegations and, on that basis, denies thern.
`
`SONY EXHIBIT 1002 - 0263
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`SONY EXHIBIT 1002 - 0263
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`

`
`"fl.
`
`The allegations of Paragraph ’7l are not directed to Bl,ueAnt and therefore no
`
`answer is required, To the extent an answer is required, BlueAnt lacks sufficient lrnowledge or
`
`inforrnation on which to adniit or deny such allegations and, on that basis, denies thern.
`
`72.
`
`The allegati,oris of Paragraph '72 are not directed to BlueAn,t and therefore no
`
`answer is required. To the extent an answer is required, BlueAnt lacks sufficient. knowledge or
`
`inforrnation on which to admit or deny such allegations and, on that basis, denies thern.
`
`73.
`
`The allegations of Paragraph 73 are not directed to Bl,ueAnt and therefore no
`
`answer is required, To the extent an answer is required, BlueAnt lacks sufficient lrnowledge or
`
`inforrnation on which to adniit or deny such allegations and, on that basis, denies thern.
`
`74.
`
`The allegations of Paragraph 74 are not directed to l%lueAnt and therefore no
`
`answer is required. To the extent an answer is required, BlueAnt lacks sufficient. knowledge or
`
`inforrnation on which to admit or deny such allegations and, on that basis, denies thern.
`
`75.
`
`The allegations of Paragraph 75 are not directed to Bl,ueAnt and therefore no
`
`answer is required, To the extent an answer is required, BlueAnt lacks sufficient lrnowledge or
`
`inforrnation on which to adniit or deny such allegations and, on that basis, denies thern.
`
`G,
`
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`{}n,e-E-'Wav’s A_l_leat_lons For abra
`
`76.
`
`The allegations of Paragraph 76 are not direete.d to BlueAnt and therefore no
`
`answer is required, To the extent an answer is required, BlueAnt lacks sufficient l<:nowledge or
`
`l,I1fO1'D,‘l£ilLl()t‘l, on which to adniit or deny saeh allegations and, on that basis, denies them.
`
`77.
`
`The allegations of Paragraph 77 are not directed to Bill‘?/.LAl._I1t and therefore no
`
`answer is required. To the extent an answer is required, l3lueAnt lacks sufficient knowledge or
`
`inforrnation on which to admit or deny such allegations and, on that basis, denies then].
`
`78.
`
`The allegations of Paragraph 78 are not direete.d to BlueAnt and therefore no
`
`answer is required, To the extent an answer is required, BlueAnt lacks sufficient l<:nowledge or
`
`l,I1fO1'D,‘l£ilLl()t‘l, on which to adniit or deny saeh allegations and, on that basis, denies them.
`
`79.
`
`The allegations of Paragraph 79 are not directed to Bill‘?/.LAl._I1t and therefore no
`
`answer is required. To the extent an answer is required, l3lueAnt lacks sufficient knowledge or
`
`inforrnation on which to admit or deny such allegations and, on that basis, denies then].
`
`SONY EXHIBIT 1002 - 0264
`
`SONY EXHIBIT 1002 - 0264
`
`

`
`80.
`
`The allegations of Paragraph 80 are not directed to Bl.ueAnt and therefore no
`
`answer is required. To the extent an answer is required, BlueAnt lacks sufficient lsmowledge or
`
`information on which to admit or deny such allegations and, on that basis, denies them.
`
`8l.
`
`The allegati.oris of Paragraph 8l are not directed to BlueAn,t and therefore no
`
`answer is required. To the extent an answer is required, BlueAnt lacks sufficient. knowledge or
`
`information on which to admit or deny such allegations and, on that basis, denies them.
`
`82.
`
`The allegations of Paragraph 82 are not directed to Bl.ueAnt and therefore no
`
`answer is required. To the extent an answer is required, BlueAnt lacks sufficient lsmowledge or
`
`information on which to admit or deny such allegations and, on that basis, denies them.
`
`VET.
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`ONE-E-=W’AY’. Alil.l7,‘Gl7il3 SPECEFIC INSTANCES OF UNFAIR
` . ‘UR
`
`83.
`
`The allegations