`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`Washington, D.C.
`
`Before the Honorable Thomas B. Pender
`Administrative Law Judge
`
`
`
`
`
`
`Investigation No. 337-TA-1057
`
`In the Matter of
`
`CERTAIN ROBOTIC VACUUM
`CLEANING DEVICES AND
`COMPONENTS THEREOF SUCH AS
`SPARE PARTS
`
`
`
`RESPONDENTS HOOVER INC. AND ROYAL APPLIANCE
`MANUFACTURING CO. D/B/A TTI FLOOR CARE NORTH AMERICA, INC.’S
`RESPONSE TO THE COMPLAINT AND THE NOTICE OF INVESTIGATION
`
`Respondents Hoover Inc. (“Hoover”) and Royal Appliance Manufacturing Co. d/b/a TTi
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`Floor Care North America, Inc. (“Royal”) (collectively, the “Hoover Respondents”), pursuant to
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`19 C.F.R. § 210.13, respectfully submit this Response to the Complaint of iRobot Corporation
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`(“iRobot” or “Complainant”) under Section 337 of the Tariff Act of 1930, as Amended (the
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`“Complaint”), and the Notice of Investigation (the “Notice of Investigation”).
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`RESPONSE TO THE COMPLAINT
`
`The Hoover Respondents respond to the Complaint dated April 17, 2017, and entitled
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`“Verified Complaint of iRobot Corporation Under Section 337 of the Tariff Act of 1930, as
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`Amended,” in like-numbered paragraphs, as follows. Certain headings are reproduced from the
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`Complaint for the sake of convenience but are not an admission of the content of the Complaint
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`or the specific allegations therein. Any allegations not specifically admitted are hereby denied.
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`I.
`
`
`INTRODUCTION
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`1.1
`
`The Hoover Respondents admit that iRobot has requested that the United States
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`International Trade Commission (the “Commission”) institute an investigation under Section 337
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`
`
`1
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`IROBOT 2014
`Shenzhen Silver Star v. iRobot
`IPR2018-00897
`
`
`
`PUBLIC VERSION
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`of the Tariff Act of 1930, as amended, 19 U.S.C. § 1337. The Hoover Respondents deny that
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`they have unlawfully imported, sold for importation, and/or sold after importation in the United
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`States any robotic vacuum cleaning devices or components thereof that infringe any valid and
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`enforceable United States patent owned by iRobot.
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`1.2
`
`The Hoover Respondents admit that the Complaint names Bissell Homecare, Inc.,
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`Hoover Inc., Royal Appliance Manufacturing Co. Inc. d/b/a TTi Floor Care North America, Inc.,
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`Bobsweep, Inc., Bobsweep USA, The Black & Decker Corporation, Black & Decker (U.S.) Inc.,
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`Shenzhen Zhi Yi Technology Co., Ltd. d/b/a iLife, Matsutek Enterprises Co., Ltd., Suzhou Real
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`Power Electric Appliance Co., Ltd., and Shenzhen Silver Start Intelligent Technology Co., Ltd.
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`as proposed respondents (collectively, “Proposed Respondents”). The Hoover Respondents deny
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`that they have engaged in any unfair acts in violation of Section 337, including the unlicensed
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`importation, sale for importation, and/or sale after importation in the United States of any
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`Accused Products that infringe one or more claims of U.S. Patent Nos. 7,155,308 (the “’308
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`patent”); 8,474,090 (the “’090 patent”); 8,600,553 (the “’533 patent”); 9,038,233 (the “’233
`
`patent”); and/or 9,486,924 (the “’924 patent”) (collectively, the “Asserted Patents”). To the
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`extent that this paragraph contains any other factual allegations, the Hoover Respondents lack
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`sufficient knowledge or information to admit or deny the allegations and therefore deny the
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`same.
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`1.3
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`The Hoover Respondents deny that they directly infringe, contributorily infringe,
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`and/or induce the infringement of any claim of the Asserted Patents, including the claims
`
`identified in this paragraph. To the extent that this paragraph contains any other factual
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`allegations, the Hoover Respondents lack sufficient knowledge or information to admit or deny
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`the allegations and therefore deny the same.
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`
`
`2
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`PUBLIC VERSION
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`1.4
`
`The Hoover Respondents admit that documents purporting to be certified copies
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`of the Asserted Patents are attached to the Complaint as Exhibits 1-6. The Hoover Respondents
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`further admit that documents purporting to be certified copies of the recorded assignments are
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`attached to the Complaint as Exhibits 7-12. The Hoover Respondents lack sufficient knowledge
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`or information to admit or deny the remaining allegations of paragraph 1.4 and therefore deny
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`the same.
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`1.5
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 1.5 and therefore deny the same.
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`1.6
`
`The Hoover Respondents admit that iRobot seeks certain relief under Section
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`337(d) and (f) and that iRobot seeks the imposition of a bond during any Presidential review
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`period. The Hoover Respondents deny the existence of the predicates and requirements for
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`liability under Section 337 and therefore deny that iRobot is entitled to any relief, including the
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`requested relief, as a result of this Investigation. To the extent that this paragraph contains any
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`other factual allegations, they are denied.
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`II.
`
`
`COMPLAINANT
`
`2.1
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`The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 2.1 and therefore deny the same.
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`2.2
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`The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 2.2 and therefore deny the same.
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`2.3
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 2.3 and therefore deny the same.
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`2.4
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`The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 2.4 and therefore deny the same.
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`
`
`3
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`
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`PUBLIC VERSION
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`2.5
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`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 2.5 and therefore deny the same.
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`2.6
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 2.6 and therefore deny the same.
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`2.7
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`The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 2.7 and therefore deny the same.
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`III.
`
`
`PROPOSED RESPONDENTS
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`A.
`
`3.1
`
`Bissell Homecare, Inc.
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`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.1 and therefore deny the same.
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`3.2
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`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.2 and therefore deny the same.
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`3.3
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.3 and therefore deny the same.
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`B.
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`3.4
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`3.5
`
`Hoover, Inc.
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`The Hoover Respondents admit the allegations in paragraph 3.4.
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`The Hoover Respondents admit that Exhibit 14 is a document purporting to be a
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`copy of a page from the website https://hoover.com/products/category/robot-vacuums/. The
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`Hoover Respondents further admit that the Quest ™ line of products includes the Quest 700
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`(Model BH70700), Quest 800 (Model70800), and Quest 1000 (Model BH71000) robot vacuums
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`(hereinafter, “Hoover Accused Products”). The Hoover Respondents further admit that they
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`offer to sell the Hoover Accused Products.
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`3.6
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`[
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`
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`4
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`
`
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`PUBLIC VERSION
`
` ] The Hoover
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`Respondents further admit that Royal imports the Hoover Accused Products into the United
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`States. The Hoover Respondents further admit that Royal sells the Hoover Accused Products in
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`the United States following importation.
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`
`
`C.
`
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`3.7
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`3.8
`
`Royal Appliance Manufacturing Co. Inc. d/b/a TTi Floor Care North
`America, Inc.
`
`The Hoover Respondents admit the allegations in paragraph 3.7.
`
`[
`
`
`
` ] The Hoover Respondents further admit
`
`that Royal imports the Hoover Accused Products into the United States. The Hoover
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`Respondents further admit that Royal sells the Hoover Accused Products in the United States
`
`following importation.
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`3.9
`
`The Hoover Respondents admit that Exhibit 16 is a document purporting to be a
`
`copy of a page from the website https://hoover.com/products/category/robot-vacuums/ that states
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`“Today, Hoover is part of TTI Floor Care North America, Headquartered in Glenwillow, OH.”
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`The Hoover Respondents admit that Exhibit 17 is a document purporting to be a copy of a TTi
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`Floor Care North America website that states “Hoover: We acquired this marquee brand in
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`2007.” The Hoover Respondents deny that Exhibit 17, which purports to be a copy of the TTi
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`Floor Care North America website, includes a link to the Hoover sales website. To the extent
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`that this paragraph contains any other factual allegations, the Hoover Respondents lack sufficient
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`knowledge or information to admit or deny the allegations and therefore deny the same.
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`Bobsweep, Inc.
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`D.
`
`3.10 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.10 and therefore deny the same.
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`
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`5
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`
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`PUBLIC VERSION
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`3.11 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.11 and therefore deny the same.
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`3.12 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.12 and therefore deny the same.
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`Bobsweep USA
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`E.
`
`3.13 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.13 and therefore deny the same.
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`3.14 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.14 and therefore deny the same.
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`3.15 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.15 and therefore deny the same.
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`The Black & Decker Corporation
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`F.
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`3.16 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.16 and therefore deny the same.
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`3.17 The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 3.17 and therefore deny the same.
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`3.18 The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 3.18 and therefore deny the same.
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`3.19 The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 3.19 and therefore deny the same.
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`
`
`6
`
`
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`PUBLIC VERSION
`
`Black & Decker (U.S.) Inc.
`
`G.
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`3.20 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.20 and therefore deny the same.
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`3.21 The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 3.21 and therefore deny the same.
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`3.22 The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 3.22 and therefore deny the same.
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`Shenzhen ZhiYi Technology Co., Ltd. d/b/a iLife
`
`H.
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`3.23 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.23 and therefore deny the same.
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`3.24 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.24 and therefore deny the same.
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`3.25 The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 3.25 and therefore deny the same.
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`Matsutek Enterprises Co., Ltd.
`
`I.
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`3.26 The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 3.26 and therefore deny the same.
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`3.27 The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 3.27 and therefore deny the same.
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`3.28 The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 3.28 and therefore deny the same.
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`Suzhou Real Power Electric Appliance Co., Ltd.
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`J.
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`3.29 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`
`
`7
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`
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`PUBLIC VERSION
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`deny the allegations of paragraph 3.29 and therefore deny the same.
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`3.30 The Hoover Respondents admit that Suzhou Real Power Electric Appliance Co.,
`
`Ltd. (“Real Power”) manufactures certain of the Hoover Accused Products at least in China. To
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`the extent that this paragraph contains any other factual allegations, the Hoover Respondents lack
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`sufficient knowledge or information to admit or deny the allegations and therefore deny the
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`same.
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`3.31 The Hoover Respondents admit that Exhibits 34 and 35 purport to identify Real
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`Power as manufacturer of Hoover robot vacuum models BH70700 and BH70800. The Hoover
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`Respondents further admit that Exhibit 36 purports to identify Real Power as the shipper of
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`“Vacuum Cleaner Spare Parts – Robots” to Royal. The Hoover Respondents further admit that
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`Exhibit 37 purports to identify Real Power as the “Manufacturer” of the BH70700 robot vacuum
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`cleaner. To the extent that this paragraph contains any other factual allegations, the Hoover
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`Respondents lack sufficient knowledge or information to admit or deny the allegations and
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`therefore deny the same.
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`Shenzhen Silver Start Intelligent Technology Co., Ltd.
`
`K.
`
`3.32 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 3.32 and therefore deny the same.
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`3.33 The Hoover Respondents admit that Shenzhen Silver Star Intelligent Technology
`
`Co., Ltd. (“Silver Star”) manufactures certain of the Hoover Accused Products at least in China.
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`To the extent that this paragraph contains any other factual allegations, the Hoover Respondents
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`lack sufficient knowledge or information to admit or deny the allegations and therefore deny the
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`same.
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`
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`3.34 The Hoover Respondents admit that Exhibits 38 purports to identify Silver Star as
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`8
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`
`
`PUBLIC VERSION
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`manufacturer of Hoover robot vacuum model BH71000. To the extent that this paragraph
`
`contains any other factual allegations, the Hoover Respondents lack sufficient knowledge or
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`information to admit or deny the allegations and therefore deny the same.
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`3.35 The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 3.35 and therefore deny the same.
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`3.36 The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 3.36 and therefore deny the same.
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`IV.
`
`
`THE TECHNOLOGY AND PRODUCTS AT ISSUE
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`4.1
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 4.1 and therefore deny the same.
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`4.2
`
`The Hoover Respondents admit that the Complainant identifies the Hoover
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`Accused Products as Accused Products. The Hoover Respondents deny that any of its products,
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`including the Hoover Accused Products, infringe any valid or enforceable claim of any Asserted
`
`Patent. To the extent that this paragraph contains any other factual allegations, the Hoover
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`Respondents lack sufficient knowledge or information to admit or deny the allegations and
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`therefore deny the same.
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`4.3
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 4.3 and therefore deny the same.
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`4.4
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 4.4 and therefore deny the same.
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`4.5
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`The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 4.5 and therefore deny the same.
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`4.6
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`The Hoover Respondents admit that paragraph 4.6 identifies the Quest 700
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`
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`9
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`
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`PUBLIC VERSION
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`(Model BH70700), Quest 800 (Model BH70800), and Quest 1000 (Model BH71000) as
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`examples of the Hoover Accused Products. Hoover denies that any of its products, including the
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`Hoover Accused Products, infringes any valid and enforceable claim of the Asserted Patents. To
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`the extent that this paragraph contains any other factual allegations, they are denied.
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`4.7
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 4.7 and therefore deny the same.
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`4.8
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 4.8 and therefore deny the same.
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`4.9
`
`The Hoover Respondents lack sufficient knowledge or information to admit or
`
`deny the allegations of paragraph 4.9 and therefore deny the same.
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`4.10
`
`[
`
`
`
` ] The Hoover Respondents further admit
`
`that Royal imports the Hoover Accused Products into the United States. Hoover further admits
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`that Royal sells the Hoover Accused Products in the United States following their importation.
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`To the extent that this paragraph contains any other factual allegations, the Hoover Respondents
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`lack sufficient knowledge or information to admit or deny the allegations and therefore deny the
`
`same.
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`V.
`
`
`THE ASSERTED PATENTS
`
`A.
`
`
`5.1
`
`U.S. Patent No. 6,809,490
`
`1.
`
`Identification of the Patent and Ownership by iRobot
`
`The Hoover Respondents admit that Exhibit 1 is a document purporting to be U.S.
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`Patent No. 6,890,490 (“the ’490 Patent”) entitled “Methods and Systems for Multi-Mode
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`Coverage for an Autonomous Robot” and purporting to be issued on October 26, 2004. The
`
`
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`10
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`
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`PUBLIC VERSION
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`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.1 and therefore deny the same.
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`5.2
`
`The Hoover Respondents admit that on its face the ’490 patent has seven
`
`independent claims and 35 dependent claims. The Hoover Respondents lack sufficient
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`knowledge or information to admit or deny the remaining allegations of paragraph 5.2 and
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`therefore deny the same.
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`5.3
`
`The Hoover Respondents admit that Exhibit 7 contains documents purporting to
`
`be assignments of all right, title and interest in U.S. Patent Application Serial No. 10/167,851
`
`recorded at the United States Patent and Trademark Office at Reel/Frame 014249/705 and
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`014249/711. The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 5.3 and therefore deny the same.
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`5.4
`
`The Hoover Respondents admit that Appendices A and G, respectively, purport to
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`contain: A) a certified copy and three additional copies of the prosecution history of the ’490
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`Patent; and B) four copies of examiner-cited references mentioned in that prosecution history.
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`The Hoover Respondents lack sufficient knowledge or information to admit or deny the
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`allegations of paragraph 5.4 and therefore deny the same.
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`2.
`
`Non-Technical Description of the Patented Invention
`
`To the extent that paragraph 5.5 states legal conclusions regarding the alleged
`
`5.5
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`scope of the ’490 patent, no response is required. To the extent that a response is required, the
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
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`paragraph 5.5 and therefore deny the same.
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`3.
`
`Foreign Counterparts to the ’490 Patent
`
`The Hoover Respondents admit that paragraph 5.6 contains a table of foreign
`
`5.6
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`
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`11
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`
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`PUBLIC VERSION
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`patents and/or patent applications that are allegedly “counterparts” to the ’490 patent. The
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`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
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`paragraph 5.6 and therefore deny the same.
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`4.
`
`Licenses
`
`The Hoover Respondents admit that Confidential Exhibit 40 is a document
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`
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`5.7
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`purporting to be a list of licensed entities. The Hoover Respondents lack sufficient knowledge or
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`information to admit or deny the remaining allegations of paragraph 5.7 and therefore deny the
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`same.
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`B.
`
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`5.8
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`U.S. Patent No. 7,155,308
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`1.
`
`Identification of the Patent and Ownership by iRobot
`
`The Hoover Respondents admit that Exhibit 2 is a document purporting to be U.S.
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`Patent No. 7,155,308 (“the ’308 Patent”) entitled “Robot Obstacle Detection System” and
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`purporting to be issued on December 26, 2006. The Hoover Respondents lack sufficient
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`knowledge or information to admit or deny the allegations of paragraph 5.8 and therefore deny
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`the same.
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`5.9
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`The Hoover Respondents admit that on its face the ’308 patent has two
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`independent claims and 32 dependent claims. The Hoover Respondents lack sufficient
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`knowledge or information to admit or deny the remaining allegations of paragraph 5.9 and
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`therefore deny the same.
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`5.10 The Hoover Respondents admit that Exhibit 8 contains documents purporting to
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`be assignments of all right, title and interest in U.S. Patent Application Serial No. 10/453,202
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`recorded at the United States Patent and Trademark Office at Reel/Frame 014150/455. The
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`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`
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`12
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`
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`PUBLIC VERSION
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`paragraph 5.10 and therefore deny the same.
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`5.11 The Hoover Respondents admit that Appendices B and H, respectively, purport to
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`contain: C) a certified copy and three additional copies of the prosecution history of the ’308
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`Patent; and D) four copies of examiner-cited references mentioned in that prosecution history.
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`The Hoover Respondents lack sufficient knowledge or information to admit or deny the
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`allegations of paragraph 5.11 and therefore deny the same.
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`2.
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`Non-Technical Description of the Patented Invention
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`5.12 To the extent that paragraph 5.12 states legal conclusions regarding the alleged
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`scope of the ’308 patent, no response is required. To the extent that a response is required, the
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
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`paragraph 5.12 and therefore deny the same.
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`3.
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`Foreign Counterparts to the ’308 Patent
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`5.13 The Hoover Respondents lack sufficient knowledge or information to admit or
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`deny the allegations of paragraph 5.13 and therefore deny the same.
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`4.
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`Licenses
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`5.14 The Hoover Respondents admit that Confidential Exhibit 40 is a document
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`
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`purporting to be a list of licensed entities. The Hoover Respondents lack sufficient knowledge or
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`information to admit or deny the remaining allegations of paragraph 5.14 and therefore deny the
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`same.
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`U.S. Patent No. 8,474,090
`
`C.
`
`
`1.
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`Identification of the Patent and Ownership by iRobot
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`5.15 The Hoover Respondents admit that Exhibit 3 is a document purporting to be U.S.
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`Patent No. 8,474,090 (“the ’090 Patent”) entitled “Autonomous Floor-Cleaning Robot” and
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`purporting to be issued on July 2, 2013. The Hoover Respondents lack sufficient knowledge or
`13
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`
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`PUBLIC VERSION
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`information to admit or deny the allegations of paragraph 5.15 and therefore deny the same.
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`5.16 The Hoover Respondents admit that on its face the ’090 patent has three
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`independent claims and 17 dependent claims. The Hoover Respondents lack sufficient
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`knowledge or information to admit or deny the remaining allegations of paragraph 5.16 and
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`therefore deny the same.
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`5.17 The Hoover Respondents admit that Exhibit 9 contains documents purporting to
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`be assignments of all right, title and interest in U.S. Patent Application Serial No. 12/201,554
`
`recorded at the United States Patent and Trademark Office at Reel/Frame 0286625/471. The
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`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.17 and therefore deny the same.
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`5.18 The Hoover Respondents admit that Appendices C and I, respectively, purport to
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`contain: E) a certified copy and three additional copies of the prosecution history of the ’090
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`Patent; and F) four copies of examiner-cited references mentioned in that prosecution history.
`
`The Hoover Respondents lack sufficient knowledge or information to admit or deny the
`
`allegations of paragraph 5.18 and therefore deny the same.
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`2.
`
`Non-Technical Description of the Patented Invention
`
`5.19 To the extent that paragraph 5.19 states legal conclusions regarding the alleged
`
`scope of the ’090 patent, no response is required. To the extent that a response is required, the
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.19 and therefore deny the same.
`
`3.
`
`Foreign Counterparts to the ’090 Patent
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`5.20 The Hoover Respondents admit that paragraph 5.20 contains a table of foreign
`
`
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`patents and/or patent applications that are allegedly “counterparts” to the [sic] ’553 patent. The
`
`
`
`14
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`PUBLIC VERSION
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`Hoover Respondents lack sufficient knowledge or information to admit or deny the remaining
`
`allegations of paragraph 5.20 and therefore deny the same.
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`4.
`
`Licenses
`
`5.21 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`
`
`deny the allegations of paragraph 5.21 and therefore deny the same.
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`U.S. Patent No. 8,600,553
`
`D.
`
`
`1.
`
`Identification of the Patent and Ownership by iRobot
`
`5.22 The Hoover Respondents admit that Exhibit 4 is a document purporting to be U.S.
`
`Patent No. 8,600,553 (“the ’553 Patent”) entitled “Coverage Robot Mobility” and purporting to
`
`be issued on December 3, 2013. The Hoover Respondents lack sufficient knowledge or
`
`information to admit or deny the allegations of paragraph 5.22 and therefore deny the same.
`
`5.23 The Hoover Respondents admit that on its face the ’553 patent has three
`
`independent claims and 22 dependent claims. The Hoover Respondents lack sufficient
`
`knowledge or information to admit or deny the remaining allegations of paragraph 5.23 and
`
`therefore deny the same.
`
`5.24 The Hoover Respondents admit that Exhibit 10 contains documents purporting to
`
`be assignments of all right, title and interest in U.S. Patent Application Serial No. 11/758,289
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`recorded at the United States Patent and Trademark Office at Reel/Frame 020893/176. The
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.24 and therefore deny the same.
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`5.25 The Hoover Respondents admit that Appendices D and J, respectively, purport to
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`contain: G) a certified copy and three additional copies of the prosecution history of the ’553
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`Patent; and H) four copies of examiner-cited references mentioned in that prosecution history.
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`15
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`PUBLIC VERSION
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`The Hoover Respondents lack sufficient knowledge or information to admit or deny the
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`allegations of paragraph 5.25 and therefore deny the same.
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`2.
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`Non-Technical Description of the Patented Invention
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`5.26 To the extent that paragraph 5.26 states legal conclusions regarding the alleged
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`scope of the ’553 patent, no response is required. To the extent that a response is required, the
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`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.26 and therefore deny the same.
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`3.
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`Foreign Counterparts to the ’553 Patent
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`5.27 The Hoover Respondents admit that paragraph 5.27 contains a table of foreign
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`patents and/or patent applications that are allegedly “counterparts” to the ’553 patent. The
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`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
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`paragraph 5.27 and therefore deny the same.
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`4.
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`Licenses
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`5.28 The Hoover Respondents lack sufficient knowledge or information to admit or
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`
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`deny the allegations of paragraph 5.28 and therefore deny the same.
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`U.S. Patent No. 9,038,233
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`E.
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`1.
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`Identification of the Patent and Ownership by iRobot
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`5.29 The Hoover Respondents admit that Exhibit 5 is a document purporting to be U.S.
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`Patent No. 9,038,233 (“the ’233 Patent”) entitled “Autonomous Floor-Cleaning Robot” and
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`purporting to be issued on May 26, 2015. The Hoover Respondents lack sufficient knowledge or
`
`information to admit or deny the allegations of paragraph 5.29 and therefore deny the same.
`
`5.30 The Hoover Respondents admit that on its face the ’233 patent has two
`
`independent claims and 19 dependent claims. The Hoover Respondents lack sufficient
`
`knowledge or information to admit or deny the remaining allegations of paragraph 5.30 and
`16
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`PUBLIC VERSION
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`therefore deny the same.
`
`5.31 The Hoover Respondents admit that Exhibit 11 contains documents purporting to
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`be assignments of all right, title and interest in U.S. Patent Application Serial No. 13/714,546
`
`recorded at the United States Patent and Trademark Office at Reel/Frame 030046/817. The
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.31 and therefore deny the same.
`
`5.32 The Hoover Respondents admit that Appendices E and K, respectively, purport to
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`contain: I) a certified copy and three additional copies of the prosecution history of the ’233
`
`Patent; and J) four copies of examiner-cited references mentioned in that prosecution history.
`
`The Hoover Respondents lack sufficient knowledge or information to admit or deny the
`
`allegations of paragraph 5.32 and therefore deny the same.
`
`2.
`
`Non-Technical Description of the Patented Invention
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`5.33 To the extent that paragraph 5.33 states legal conclusions regarding the alleged
`
`scope of the ’233 patent, no response is required. To the extent that a response is required, the
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.33 and therefore deny the same.
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`3.
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`Foreign Counterparts to the ’233 Patent
`
`5.34 The Hoover Respondents admit that paragraph 5.34 contains a table of foreign
`
`patents and/or patent applications that are allegedly “counterparts” to the ’233 patent. The
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.34 and therefore deny the same.
`
`4.
`
`Licenses
`
`5.35 The Hoover Respondents lack sufficient knowledge or information to admit or
`
`
`
`deny the allegations of paragraph 5.35 and therefore deny the same.
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`17
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`PUBLIC VERSION
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`U.S. Patent No. 9,486,924
`
`F.
`
`
`1.
`
`Identification of the Patent and Ownership by iRobot
`
`5.36 The Hoover Respondents admit that Exhibit 6 is a document purporting to be U.S.
`
`Patent No. 9,486,924 (“the ’924 Patent”) entitled “Remote Control Scheduler and Method for
`
`Autonomous Robotic Device” and purporting to be issued on November 8, 2015. The Hoover
`
`Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.36 and therefore deny the same.
`
`5.37 The Hoover Respondents admit that on its face the ’924 patent has two
`
`independent claims and 17 dependent claims. The Hoover Respondents lack sufficient
`
`knowledge or information to admit or deny the remaining allegations of paragraph 5.37 and
`
`therefore deny the same.
`
`5.38 The Hoover Respondents admit that Exhibit 12 contains documents purporting to
`
`be assignments of all right, title and interest in U.S. Patent Application Serial No. 14/670,572
`
`recorded at the United States Patent and Trademark Office at Reel/Frame 035655/501. The
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.38 and therefore deny the same.
`
`5.39 The Hoover Respondents admit that Appendices F and L, respectively, purport to
`
`contain: K) a certified copy and three additional copies of the prosecution history of the ’924
`
`Patent; and L) four copies of examiner-cited references mentioned in that prosecution history.
`
`The Hoover Respondents lack sufficient knowledge or information to admit or deny the
`
`allegations of paragraph 5.39 and therefore deny the same.
`
`2.
`
`Non-Technical Description of the Patented Invention
`
`5.40 To the extent that paragraph 5.40 states legal conclusions regarding the alleged
`
`scope of the ’924 patent, no response is required. To the extent that a response is required, the
`18
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`
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`PUBLIC VERSION
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the allegations of
`
`paragraph 5.40 and therefore deny the same.
`
`3.
`
`Foreign Counterparts to the ’924 Patent
`
`5.41 The Hoover Respondents admit that paragraph 5.34 contains a table of foreign
`
`patents and/or patent applications that are allegedly “counterparts” to the ’924 patent. The
`
`Hoover Respondents lack sufficient knowledge or information to admit or deny the remaining
`
`allegations of paragraph 5.41 and therefore deny the same.
`
`4.
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`Licenses
`
`5.42 The Hoover Respondents lack sufficient knowledge or information to admit or
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`
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`deny the allegations of paragraph 5.42 and therefore deny the same.
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`VI.
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`SPECIFIC INSTANCES OF UN