Case 2:17-cv-00124-JRG Document 33 Filed 06/05/17 Page 1 of 13 PageID #: 252
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`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`FUNDAMENTAL INNOVATION
` SYSTEMS INTERNATIONAL, LLC,
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`Plaintiff,
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`v.
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`ZTE CORPORATION, et al.,
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`Defendants.
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`Case No. 2:17-cv-124-JRG
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`DEFENDANT ZTE TX INC.’S ANSWER
`TO PLAINTIFF’S AMENDED COMPLAINT
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`Defendant ZTE TX Inc. (“ZTE TX”) responds to Plaintiff’s Amended Complaint as
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`follows. This Answer is solely on behalf of ZTE TX and is not on behalf of Defendant ZTE
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`Corporation or Defendant ZTE (USA) Inc.
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`PARTIES
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`1.
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`ZTE TX lacks knowledge or information sufficient to form a belief about the truth
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`of the allegations in paragraph 1 of the Amended Complaint and therefore denies the same.
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`2.
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`ZTE TX lacks knowledge or information sufficient to form a belief about the truth
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`of the allegations in paragraph 2 of the Amended Complaint and therefore denies the same.
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`3.
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`ZTE TX admits that ZTE Corporation is organized and existing under the laws of
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`China with its principal place of business at No. 55, Hitech Road South, Shenzhen, China
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`518057. Except as expressly admitted, ZTE TX denies the allegations in paragraph 3 of the
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`Amended Complaint.
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`4.
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`ZTE TX admits that ZTE (USA) Inc. is a New Jersey corporation. ZTE TX
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`admits that ZTE (USA) Inc. sells consumer electronics. Except as expressly admitted, ZTE TX
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`denies the allegations in paragraph 4 of the Amended Complaint.
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`5.
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`ZTE TX admits that ZTE TX is a Texas corporation that may be served through
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`its registered agent, Ferguson, Braswell & Fraser, PC, 2500 Dallas Parkway, Suite 501, Plano,
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`Texas 75093. ZTE TX denies that it sells consumer electronics, mobile phones, and related
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`accessories. Except as expressly admitted, ZTE TX denies the allegations in paragraph 5 of the
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`Amended Complaint.
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`6.
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`The allegations in paragraph 6 of the Complaint express legal conclusions to
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`which no response is required. To the extent that a response is required, ZTE TX admits that
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`ZTE (USA) Inc. identifies with the trade name “ZTE.” ZTE TX admits that ZTE (USA) Inc.
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`sells products in the United States. ZTE TX specifically denies that ZTE TX has committed acts
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`of infringement under any theory of infringement in this judicial district or elsewhere in the
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`United States. Except as expressly admitted, ZTE TX denies the allegations in paragraph 6 of
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`the Amended Complaint.
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`JURISDICTION AND VENUE
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`7.
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`The allegations in paragraph 7 of the Amended Complaint express legal
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`conclusions to which no response is required.
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`8.
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`The allegations in paragraph 8 of the Amended Complaint express legal
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`conclusions to which no response is required. To the extent that a response is required, ZTE TX
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`admits that ZTE TX conducts business in Texas and maintains a facility and employees within
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`Texas. ZTE TX specifically denies that ZTE TX has committed acts of infringement under any
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`theory of infringement in this judicial district or elsewhere in the United States. ZTE TX admits
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`it has a registered agent, Ferguson, Braswell & Fraser, PC, 2500 Dallas Parkway, Suite 501,
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`Plano, Texas 75093. Except as expressly admitted, ZTE TX denies the allegations in paragraph 8
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`of the Amended Complaint.
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`9.
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`ZTE TX admits that venue is proper in this judicial district. ZTE TX admits that
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`it resides and is subject to personal jurisdiction in this judicial district. ZTE TX denies that it has
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`a regular and established place of business in this judicial district. ZTE TX specifically denies
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`that ZTE TX has committed acts of infringement under any theory of infringement in this
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`judicial district or elsewhere in the United States. Except as expressly admitted, ZTE TX denies
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`the allegations in paragraph 9 of the Amended Complaint.
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`FACTUAL ALLEGATIONS
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`10.
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`11.
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`ZTE TX denies every allegation in paragraph 10 of the Amended Complaint.
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`ZTE TX lacks knowledge or information sufficient to form a belief about the truth
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`of the allegations in paragraph 11 of the Amended Complaint and therefore denies the same.
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`12.
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`ZTE TX lacks knowledge or information sufficient to form a belief about the truth
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`of the allegations in paragraph 12 of the Amended Complaint and therefore denies the same.
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`13.
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`14.
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`ZTE TX denies every allegation in paragraph 13 of the Amended Complaint.
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`The allegations in paragraph 14 of the Amended Complaint express legal
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`conclusions and claim language, there has been no claim construction order in this action, and
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`thus, no response is required. To the extent that a response is required, ZTE TX denies every
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`allegation in paragraph 14 of the Amended Complaint.
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`15.
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`The allegations in paragraph 15 of the Amended Complaint express legal
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`conclusions and claim language, there has been no claim construction order in this action, and
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`thus, no response is required. To the extent that a response is required, ZTE TX denies every
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`allegation in paragraph 15 of the Amended Complaint. ZTE TX denies every allegation in
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`paragraph 16 of the Amended Complaint.
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`16.
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`The allegations in paragraph 16 of the Amended Complaint express legal
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`conclusions and claim language, there has been no claim construction order in this action, and
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`thus, no response is required. To the extent that a response is required, ZTE TX denies every
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`allegation in paragraph 16 of the Amended Complaint.
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`17.
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`18.
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`19.
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`20.
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`21.
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`ZTE TX denies every allegation in paragraph 17 of the Amended Complaint.
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`ZTE TX denies every allegation in paragraph 18 of the Amended Complaint.
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`ZTE TX denies every allegation in paragraph 19 of the Amended Complaint.
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`ZTE TX denies every allegation in paragraph 20 of the Amended Complaint.
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`The allegations in paragraph 21 of the Amended Complaint express legal
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`conclusions to which no response is required. To the extent that a response is required, ZTE TX
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`specifically denies that ZTE has committed acts of infringement under any theory of
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`infringement in this judicial district or elsewhere in the United States.
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`FIRST CLAIM FOR RELIEF
`([Alleged] Infringement of U.S. Patent No. 8,232,766)
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`22.
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`ZTE TX incorporates by reference each of its responses set forth in paragraphs 1
`
`to 21 as if fully set forth herein.
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`23.
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`ZTE TX admits that Exhibit A to the Amended Complaint appears to be a copy of
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`U.S. Patent No. 8,232,766 (“the ’766 patent”). ZTE TX admits that the face of Exhibit A shows
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`the title “Multifunctional Charger System and Method.” ZTE TX admits that the face of Exhibit
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`A states that the ’766 patent issued on July 31, 2012. Except as expressly admitted, ZTE TX
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`denies the allegations in paragraph 23 of the Amended Complaint.
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`24.
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`ZTE TX admits that the face of Exhibit A indicates that the ’766 patent names
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`Daniel M. Fischer, Dan G. Radut, Michael F. Habicher, Quang A. Luong, and Jonathan T.
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`Malton as inventors. Except as expressly admitted, ZTE TX denies the allegations in paragraph
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`24 of the Amended Complaint.
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`25.
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`ZTE TX lacks knowledge or information sufficient to form a belief about the truth
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`of the allegations in paragraph 25 of the Amended Complaint and therefore denies the same.
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`26.
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`27.
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`28.
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`29.
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`30.
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`31.
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`ZTE TX denies every allegation in paragraph 26 of the Amended Complaint.
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`ZTE TX denies every allegation in paragraph 27 of the Amended Complaint.
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`ZTE TX denies every allegation in paragraph 28 of the Amended Complaint.
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`ZTE TX denies every allegation in paragraph 29 of the Amended Complaint.
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`ZTE TX denies every allegation in paragraph 30 of the Amended Complaint.
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`ZTE TX denies every allegation in paragraph 31 of the Amended Complaint.
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`SECOND CLAIM FOR RELIEF
`([Alleged] Infringement of U.S. Patent No. 7,834,586)
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`32.
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`ZTE TX incorporates by reference each of its responses set forth in paragraphs 1
`
`to 31 as if fully set forth herein.
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`33.
`
`ZTE TX admits that Exhibit B to the Amended Complaint appears to be a copy of
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`U.S. Patent No. 7,834,586 (“the ’586 patent”). ZTE TX admits that the face of Exhibit B shows
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`the title “Multifunctional Charger System and Method.” ZTE TX admits that the face of Exhibit
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`B states that the ’586 patent issued on November 16, 2010. Except as expressly admitted, ZTE
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`TX denies the allegations in paragraph 33 of the Amended Complaint.
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`34.
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`ZTE TX admits that the face of Exhibit B indicates that the ’586 patent names
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`Daniel M. Fischer, Dan G. Radut, Michael F. Habicher, Quang A. Luong, and Jonathan T.
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`Malton as inventors. Except as expressly admitted, ZTE TX denies the allegations in paragraph
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`34 of the Amended Complaint.
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`35.
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`ZTE TX lacks knowledge or information sufficient to form a belief about the truth
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`of the allegations in paragraph 35 of the Amended Complaint and therefore denies the same.
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`36.
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`37.
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`38.
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`39.
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`40.
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`41.
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`ZTE TX denies every allegation in paragraph 36 of the Amended Complaint.
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`ZTE TX denies every allegation in paragraph 37 of the Amended Complaint.
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`ZTE TX denies every allegation in paragraph 38 of the Amended Complaint.
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`ZTE TX denies every allegation in paragraph 39 of the Amended Complaint.
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`ZTE TX denies every allegation in paragraph 40 of the Amended Complaint.
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`ZTE TX denies every allegation in paragraph 41 of the Amended Complaint.
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`THIRD CLAIM FOR RELIEF
`([Alleged] Infringement of U.S. Patent No. 7,239,111)
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`42.
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`ZTE TX incorporates by reference each of its responses set forth in paragraphs 1
`
`to 41 as if fully set forth herein.
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`43.
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`ZTE TX admits that Exhibit C to the Amended Complaint appears to be a copy of
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`U.S. Patent No. 7,239,111 (“the ’111 patent”). ZTE TX admits that the face of Exhibit C shows
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`the title “Universal Serial Bus Adapter For A Mobile Device.” ZTE TX admits that the face of
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`Exhibit C indicates that the ’111 patent issued on July 3, 2007. Except as expressly admitted,
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`ZTE TX denies the allegations in paragraph 43 of the Amended Complaint.
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`44.
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`ZTE TX admits that the face of Exhibit C indicates that the ’111 patent names
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`Daniel M. Fischer, Dan G. Radut, Michael F. Habicher, Quang A. Luong, and Jonathan T.
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`Malton as inventors. Except as expressly admitted, ZTE TX denies the allegations in paragraph
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`44 of the Amended Complaint.
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`45.
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`ZTE TX lacks knowledge or information sufficient to form a belief about the truth
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`of the allegations in paragraph 45 of the Amended Complaint and therefore denies the same.
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`46.
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`ZTE TX denies the allegations in paragraph 46 of the Amended Complaint.
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`47.
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`48.
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`49.
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`50.
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`51.
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`ZTE TX denies the allegations in paragraph 47 of the Amended Complaint.
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`ZTE TX denies the allegations in paragraph 48 of the Amended Complaint.
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`ZTE TX denies the allegations in paragraph 49 of the Amended Complaint.
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`ZTE TX denies the allegations in paragraph 50 of the Amended Complaint.
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`ZTE TX denies the allegations in paragraph 51 of the Amended Complaint.
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`FOURTH CLAIM FOR RELIEF
`([Alleged] Infringement of U.S. Patent No. 8,624,550)
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`52.
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`ZTE TX incorporates by reference each of its responses set forth in paragraphs 1
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`to 51 as if fully set forth herein.
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`53.
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`ZTE TX admits that Exhibit D to the Amended Complaint appears to be a copy of
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`U.S. Patent No. 8,624,550 (“the ’550 patent”). ZTE TX admits that the face of Exhibit D shows
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`the title “Multifunctional Charger System and Method.” ZTE TX admits that the face of Exhibit
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`D states that the ’550 patent issued on January 7, 2014. Except as expressly admitted, ZTE TX
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`denies the allegations in paragraph 53 of the Amended Complaint.
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`54.
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`ZTE TX admits that the face of Exhibit D indicates that the ’550 patent names
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`Daniel M. Fischer, Dan G. Radut, Michael F. Habicher, Quang A. Luong, and Jonathan T.
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`Malton as inventors. Except as expressly admitted, ZTE TX denies the allegations in paragraph
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`54 of the Amended Complaint.
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`55.
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`ZTE TX lacks knowledge or information sufficient to form a belief about the truth
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`of the allegations in paragraph 55 of the Amended Complaint and therefore denies the same.
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`56.
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`57.
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`58.
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`59.
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`ZTE TX denies the allegations in paragraph 56 of the Amended Complaint.
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`ZTE TX denies the allegations in paragraph 57 of the Amended Complaint.
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`ZTE TX denies the allegations in paragraph 58 of the Amended Complaint.
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`ZTE TX denies the allegations in paragraph 59 of the Amended Complaint.
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`60.
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`61.
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`ZTE TX denies the allegations in paragraph 60 of the Amended Complaint.
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`ZTE TX denies the allegations in paragraph 61 of the Amended Complaint.
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`FIFTH CLAIM FOR RELIEF
`([Alleged] Infringement of U.S. Patent No. 7,893,655)
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`
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`62.
`ZTE TX incorporates by reference each of its responses set forth in paragraphs 1
`to 61 as if fully set forth herein.
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`63.
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`ZTE TX admits that Exhibit E to the Amended Complaint appears to be a copy of
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`U.S. Patent No. 7,893,655 (“the ’655 patent”). ZTE TX admits that the face of Exhibit E shows
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`the title “Charging and Power Supply for Mobile Devices.” ZTE TX admits that the face of
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`Exhibit E states that the ’550 patent issued on February 22, 2011. Except as expressly admitted,
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`ZTE TX denies the allegations in paragraph 63 of the Amended Complaint.
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`64.
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`ZTE TX admits that the face of Exhibit E indicates that the ’655 patent names
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`Dusan Veselic as inventor. Except as expressly admitted, ZTE TX denies the allegations in
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`paragraph 64 of the Amended Complaint.
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`65.
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`ZTE TX lacks knowledge or information sufficient to form a belief about the truth
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`of the allegations in paragraph 65 of the Amended Complaint and therefore denies the same.
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`66.
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`67.
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`68.
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`69.
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`70.
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`71.
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`ZTE TX denies the allegations in paragraph 66 of the Amended Complaint.
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`ZTE TX denies the allegations in paragraph 67 of the Amended Complaint.
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`ZTE TX denies the allegations in paragraph 68 of the Amended Complaint.
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`ZTE TX denies the allegations in paragraph 69 of the Amended Complaint.
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`ZTE TX denies the allegations in paragraph 70 of the Amended Complaint.
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`ZTE TX denies the allegations in paragraph 71 of the Amended Complaint.
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`PRAYER FOR RELIEF
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`ZTE TX denies that Plaintiff is entitled to any relief from ZTE TX and denies the
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`allegations in paragraphs (A)-(G) of the “Prayer for Relief” section of the Amended Complaint.
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`DEMAND FOR JURY TRIAL
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`To the extent any response is required: Denied, except that ZTE TX below demands a
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`trial by jury on all issues so triable.
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`DEFENSES
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`ZTE TX alleges and asserts the following defenses upon information and belief in
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`response to the allegations in the Amended Complaint.
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`FIRST DEFENSE
`(Non-Infringement)
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`72.
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`ZTE TX does not and has not infringed any valid and enforceable claim of U.S.
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`Patent Nos. 7,239,111 (“the ’111 patent”), 7,834,586 (“the ’586 patent”), 8,232,766 (“the ’766
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`patent”), 8,624,550 (“the ’550 patent”) and 7,893,655 (“the ’655 patent”) (collectively, “the
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`Patents-in-Suit”).
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`SECOND DEFENSE
`(Invalidity)
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`73.
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`The claims of the Patents-in-Suit are invalid and/or void for failure to comply
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`with one or more conditions of patentability set forth in Title 35 of the United States Code,
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`including, but not limited to, Sections 101, 102, 103, and 112.
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`THIRD DEFENSE
`(Licensing and/or Exhaustion)
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`74.
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`Plaintiff’s claims for patent infringement are precluded in whole or in part (i) to
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`the extent that any allegedly infringing products or components thereof are supplied, directly or
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`indirectly, to ZTE TX by (or by ZTE TX to) any entity or entities having express or implied
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`licenses to the Patents-in-Suit and/or (ii) under the doctrine of patent exhaustion.
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`FOURTH DEFENSE
`(Unenforceability)
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`75.
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`Plaintiff is barred in whole or in part under principles of equity, including
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`prosecution laches, prosecution history estoppel and disclaimer, waiver, estoppel, and/or unclean
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`hands.
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`FIFTH DEFENSE
`(Limitation on Damages, Failure to Mark)
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`76.
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`Any claim by Plaintiff for damages is limited under 35 U.S.C. §§ 286 or 287.
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`Plaintiff is barred under 35 U.S.C. § 287 from recovering damages prior to the date of the filing
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`of the Complaint. Plaintiff is barred by 35 U.S.C. § 288 from recovering costs associated with its
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`action.
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`SIXTH DEFENSE
`(No Basis for Injunctive Relief)
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`77.
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`Plaintiff is not entitled to injunctive relief against ZTE TX at least because, on
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`information and belief: (1) Plaintiff is not competing with ZTE TX; (2) Plaintiff is not practicing
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`any alleged invention of the Patents-in-Suit; (3) Plaintiff has not suffered irreparable harm;
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`and/or (4) Plaintiff has an adequate remedy (to the extent it is entitled to any remedy, which ZTE
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`TX denies).
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`SEVENTH DEFENSE
`(Failure to State a Claim for Relief)
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`78.
`
`The Amended Complaint fails to state a claim upon which relief can be granted.
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`EIGHTH DEFENSE
`(No Exceptional Case)
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`79.
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`Plaintiff cannot prove that this is an exceptional case that would justify an award
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`of attorney fees against ZTE TX pursuant to 35 U.S.C. § 285.
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`NINTH DEFENSE
`(Failure to Mitigate Damages)
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`80.
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`Plaintiff’s claims are barred, in whole or in part, by its failure to mitigate
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`damages.
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`RESERVATION OF RIGHTS
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`81.
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`ZTE TX reserves the right to assert additional defenses as may be warranted by
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`discovery or further factual investigations in this action.
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`DEMAND FOR JURY TRIAL
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`82.
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`ZTE TX demands a trial by jury on all issues so triable.
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`PRAYER FOR RELIEF
`
`ZTE TX respectfully requests that this Court enter judgment against Plaintiff as follows:
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`1.
`
`Adjudging and declaring that ZTE TX has not infringed any claim of the Patents-
`
`in-Suit;
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`2.
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`3.
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`Adjudging and declaring that the claims of the Patents-in-Suit are invalid;
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`Dismissing the Amended Complaint with prejudice, denying every prayer for
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`relief in the Amended Complaint, and entering judgment for ZTE TX;
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`4.
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`Declaring that this case is exceptional and awarding ZTE TX its costs and
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`reasonable attorneys’ fees in defending this action; and
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`5.
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`Granting ZTE TX such other and further relief as the Court may deem necessary,
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`just, or proper.
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` Respectfully submitted,
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`
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`
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`Of counsel:
`
`Jay H. Reiziss
`MCDERMOTT WILL & EMERY LLP
`500 North Capitol Street, N.W.
`Washington, D.C. 20001
`(202) 758-8000
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`
`
`/s/ Michael S. Nadel
`Charles M. McMahon
`Hersh H. Mehta
`Michael Hemes
`MCDERMOTT WILL & EMERY LLP
`444 West Lake Street
`Chicago, Illinois 60606
`(312) 372-2000
`
`Michael S. Nadel
`Natalie A. Bennett
`MCDERMOTT WILL & EMERY LLP
`500 North Capitol Street, N.W.
`Washington, D.C. 20001
`(202) 758-8000
`
`Attorneys for Defendants
`ZTE (USA) Inc., and ZTE (TX) Inc.
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`CERTIFICATE OF SERVICE
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`
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`I hereby certify that on June 5, 2017, the foregoing was electronically filed with the
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`CM/ECF system, which will send a notification of such filing to all counsel of record, including
`as follows:
`
`
`S. Calvin Capshaw, Esq.
`Capshaw Derieux LLP
`114 East Commerce Avenue
`Gladewater, Texas 75647
`
`Edward J. DeFranco, Esq.
`Brian P. Biddinger, Esq.
`Joseph Milowic III, Esq.
`Quinn Emanuel Urquhart & Sullivan LLP
`51 Madison Avenue, 22nd Floor
`New York, New York 10010
`
`Kevin P.B. Johnson
`Quinn Emanuel Urquhart & Sullivan LLP
`555 Twin Dolphin Drive, 5th Floor
`Redwood Shores, California 94065
`
`
`
`
`
`
`
` /s/ Michael S. Nadel
` Michael S. Nadel
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