Case 1:18-cv-00826-GMS Document 12 Filed 08/17/18 Page 1 of 317 PageID #: 174
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`INGENICO INC.,
`Plaintiff,
`
`
`
`
`
`
`IOENGINE, LLC,
`Defendant.
`
`
`
`v.
`
`
`
`v.
`
`
`IOENGINE, LLC,
`Counterclaim Plaintiff,
`
`
`
`
`
`INGENICO INC.,
`INGENICO CORP.., and
`INGENICO GROUP S.A.,
`Counterclaim Defendants.
`
`
`
`
`
`
`
`
`
`
`
`C.A. No. 1:18-cv-826-GMS
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`
`
`
`
`IOENGINE, LLC’S ANSWER, AFFIRMATIVE DEFENSES, AND COUNTERCLAIMS
`
`Defendant and Counterclaim Plaintiff IOENGINE, LLC (“IOENGINE”), answers
`
`and sets forth its affirmative defenses on Plaintiff Ingenico Inc.’s Complaint, and sets forth its
`
`counterclaims against Counterclaim Defendants Ingenico Inc., Ingenico Corp. and Ingenico
`
`Group S.A. (collectively “Ingenico”) as follows:
`
`INTRODUCTION
`
`1.
`
`IOENGINE admits that IOENGINE filed an action in this Court against PayPal
`
`Holdings, Inc. (No. 1:18-cv-452-GMS). IOENGINE lacks information sufficient to form a belief
`
`as to the remaining allegations of this paragraph and thus denies them.
`
`
`
`Ingenico Inc. v. IOENGINE, LLC
`IPR2019-00879 (US 9,059,969)
`Exhibit 2030
`
`

`

`Case 1:18-cv-00826-GMS Document 12 Filed 08/17/18 Page 2 of 317 PageID #: 175
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`
`PARTIES
`
`2.
`
`IOENGINE admits the allegations in this paragraph, except that IOENGINE lacks
`
`information sufficient to form a belief as to whether Ingenico is a “leading provider.”
`
`3.
`
`IOENGINE admits that it is a limited liability company organized and existing
`
`under the laws of the State of Delaware with a principal place of business at 22 Ensign Road,
`
`Norwalk, Connecticut 06853.
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`SUBJECT MATTER JURISDICTION
`
`4.
`
`5.
`
`IOENGINE admits that this Court has subject matter jurisdiction over this action.
`
`IOENGINE admits that, on March 23, 2018, IOENGINE filed a Complaint in this
`
`District (No. 1:18-cv-452-GMS) (the “PayPal Complaint”) against PayPal Holdings, Inc.
`
`(“PayPal”). Except as expressly admitted, IOENGINE denies the remaining characterizations
`
`and allegations of this paragraph.
`
`6.
`
`IOENGINE admits that, in the PayPal Complaint, IOENGINE alleged that it is
`
`the assignee of United States Patent Nos. 8,539,047 (the “’047 Patent”), 9,059,969 (the “’969
`
`Patent”), and 9,774,703 (the “’073 Patent”) (collectively the “Patents-in-Suit”). Except as
`
`expressly admitted, IOENGINE denies the remaining characterizations and allegations of this
`
`paragraph.
`
`7.
`
`IOENGINE admits that, in the PayPal Complaint, IOENGINE alleged that PayPal
`
`infringes claims of each of the Patents-in-Suit both directly and indirectly in connection with
`
`various products, including the PayPal Mobile Card Reader, PayPal Chip and Swipe Reader, and
`
`PayPal Chip and Tap Reader (each as defined in the PayPal Complaint). Except as expressly
`
`admitted, IOENGINE denies the remaining characterizations and allegations of this paragraph.
`
`8.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`2
`
`Ingenico Inc. v. IOENGINE, LLC
`IPR2019-00879 (US 9,059,969)
`Exhibit 2030
`
`

`

`Case 1:18-cv-00826-GMS Document 12 Filed 08/17/18 Page 3 of 317 PageID #: 176
`
`
`9.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`10.
`
`The allegations in this paragraph consist of argument and legal conclusions to
`
`which no response is necessary. To the extent a response is necessary, IOENGINE denies the
`
`characterizations and allegations of this paragraph.
`
`11.
`
`The allegations in this paragraph consist of argument and legal conclusions to
`
`which no response is necessary. To the extent a response is necessary, IOENGINE denies the
`
`characterizations and allegations of this paragraph.
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`PERSONAL JURISDICTION
`
`12.
`
`For purposes of this action only, IOENGINE admits that it is subject to personal
`
`jurisdiction in this District. IOENGINE admits that it filed the PayPal Complaint in this District.
`
`Except as expressly admitted, IOENGINE denies the remaining characterizations and allegations
`
`of this paragraph.
`
`13.
`
`For purposes of this action only, IOENGINE admits that it is subject to personal
`
`jurisdiction in this District. Except as expressly admitted, IOENGINE denies the remaining
`
`characterizations and allegations of this paragraph.
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`VENUE
`
`14.
`
`IOENGINE admits that venue is proper in this District. Except as expressly
`
`admitted, IOENGINE denies the remaining characterizations and allegations of this paragraph.
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`IOENGINE’S ACCESS TO THE ACCUSED PRODUCTS
`
`15.
`
`IOENGINE admits that, in the PayPal Complaint, IOENGINE refers to certain
`
`products as having “on-board storage and processing capabilities.” Except as expressly
`
`admitted, IOENGINE denies the remaining characterizations and allegations of this paragraph.
`
`3
`
`Ingenico Inc. v. IOENGINE, LLC
`IPR2019-00879 (US 9,059,969)
`Exhibit 2030
`
`

`

`Case 1:18-cv-00826-GMS Document 12 Filed 08/17/18 Page 4 of 317 PageID #: 177
`
`
`16.
`
`IOENGINE admits that the PayPal Complaint states or includes the following:
`
`that the PayPal Mobile Card Reader contains an EFM32 TG110F32 ARM Cortex-M3 processor
`
`or its equivalent, that there is a photograph of that processor, that the PayPal Mobile Card Reader
`
`contains flash memory and RAM memory integrated into an EFM TG110F32 ARM Cortex-M3
`
`processor or its equivalent, that the PayPal Mobile Card Reader includes an audio jack
`
`communications interface, that the PayPal Mobile Card Reader’s memory stores program code
`
`configured to cause an interactive user interface to be presented on a terminal’s display, that the
`
`PayPal Mobile Card Reader’s memory stores program code configured to enable the PayPal
`
`Mobile Card Reader to receive communications resulting from user interaction, including, for
`
`example, audio communications over audio pins of an audio jack communications interface, and
`
`to cause a communication to be sent to a network server through a terminal’s network interface,
`
`and that the PayPal Mobile Card Reader’s memory stores program code to be executed by the
`
`PayPal Mobile Card Reader’s processor in response to a communication resulting from user
`
`interaction with a user interface on a terminal that is configured to cause a communication to be
`
`sent to a network server through a terminal’s network interface. Except as expressly admitted,
`
`IOENGINE denies the remaining characterizations and allegations of this paragraph.
`
`17.
`
`IOENGINE admits that the PayPal Complaint states or includes the following:
`
`that the PayPal Chip and Swipe Reader contains an ARM STM 32F103 Series microprocessor or
`
`its equivalent, that there is a photograph of that processor, that the PayPal Chip and Swipe
`
`Reader contains flash memory and SRAM memory integrated into an ARM STM 32F103 Series
`
`microprocessor or its equivalent, that the PayPal Chip and Swipe Reader contains a Bluetooth
`
`communications interface, that the PayPal Chip and Swipe Reader’s memory stores program
`
`code that is configured to cause an interactive user interface to be presented on a terminal’s
`
`4
`
`Ingenico Inc. v. IOENGINE, LLC
`IPR2019-00879 (US 9,059,969)
`Exhibit 2030
`
`

`

`Case 1:18-cv-00826-GMS Document 12 Filed 08/17/18 Page 5 of 317 PageID #: 178
`
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`display, that the PayPal Chip and Swipe Reader’s memory stores program code configured to
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`enable the PayPal Chip and Swipe Reader to receive communications resulting from user
`
`interaction and to cause a communication to be sent to a network server, and that the PayPal
`
`Chip and Swipe Reader’s memory stores program code to be executed by the PayPal Chip and
`
`Swipe Reader’s processor in response to a communication resulting from user interaction with a
`
`user interface on a terminal that is configured to cause a communication to be transmitted to a
`
`communications network. Except as expressly admitted, IOENGINE denies the remaining
`
`characterizations and allegations of this paragraph.
`
`18.
`
`IOENGINE admits that the PayPal Complaint states or includes the following:
`
`that the PayPal Chip and Tap Reader contains a Kinetis MK21FX512VMC12 microprocessor or
`
`its equivalent, that there is a photograph of that processor, that the PayPal Chip and Tap Reader
`
`contains flash memory and SRAM memory integrated into a Kinetis MK21FX512VMC12
`
`microprocessor or its equivalent, that the PayPal Chip and Tap Reader contains a Bluetooth
`
`communications interface, that the PayPal Chip and Tap Reader’s memory stores program code
`
`configured to cause an interactive user interface to be presented on a terminal’s display, that the
`
`PayPal Chip and Tap Reader’s memory stores program code configured to enable the PayPal
`
`Chip and Tap Reader to receive communications resulting from user interaction and to cause a
`
`communication to be sent to a network server through the terminal’s network interface, and that
`
`the PayPal Chip and Tap Reader’s memory stores program code to be executed by the PayPal
`
`Chip and Tap Reader’s processor in response to a communication resulting from user interaction
`
`with a user interface on a terminal that is configured to cause a communication to be sent to a
`
`network server through a terminal’s network interface. Except as expressly admitted,
`
`IOENGINE denies the remaining characterizations and allegations of this paragraph.
`
`5
`
`Ingenico Inc. v. IOENGINE, LLC
`IPR2019-00879 (US 9,059,969)
`Exhibit 2030
`
`

`

`Case 1:18-cv-00826-GMS Document 12 Filed 08/17/18 Page 6 of 317 PageID #: 179
`
`
`19.
`
`IOENGINE admits that it had possession of at least one PayPal Mobile Card
`
`Reader prior to the filing of the PayPal Complaint. Except as expressly admitted, IOENGINE
`
`lacks information sufficient to form a belief as to the remaining allegations of this paragraph and
`
`thus denies them.
`
`20.
`
`IOENGINE admits that it had possession of at least one PayPal Chip and Swipe
`
`Reader prior to the filing of the PayPal Complaint. Except as expressly admitted, IOENGINE
`
`lacks information sufficient to form a belief as to the remaining allegations of this paragraph and
`
`thus denies them.
`
`21.
`
`IOENGINE admits that it had possession of at least one PayPal Chip and Tap
`
`Reader prior to the filing of the PayPal Complaint. Except as expressly admitted, IOENGINE
`
`lacks information sufficient to form a belief as to the remaining allegations of this paragraph and
`
`thus denies them.
`
`COUNT I
`(NONINFRINGEMENT OF THE ’047 PATENT)
`
`22.
`
`IOENGINE incorporates by reference this Answer’s responses to Paragraphs 1-21
`
`of the Complaint. Except as expressly admitted above, IOENGINE denies any remaining
`
`characterizations and allegations of Paragraphs 1-21 of the Complaint.
`
`23.
`
`IOENGINE admits that it owns all right, title, and interest in the ’047 Patent,
`
`including the right to assert all causes of action arising under that patent. Except as expressly
`
`admitted, IOENGINE denies the remaining characterizations and allegations of this paragraph.
`
`24.
`
`25.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`6
`
`Ingenico Inc. v. IOENGINE, LLC
`IPR2019-00879 (US 9,059,969)
`Exhibit 2030
`
`

`

`Case 1:18-cv-00826-GMS Document 12 Filed 08/17/18 Page 7 of 317 PageID #: 180
`
`
`26.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`27.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`28.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`29.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`30.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`31.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`32.
`
`33.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`34.
`
`35.
`
`36.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE admits that the current PayPal Mobile Card Reader, PayPal Chip and
`
`Swipe Reader, and PayPal Chip and Tap Reader products do not infringe claim 5 of the ’047
`
`Patent. Except as expressly admitted, IOENGINE denies the remaining characterizations and
`
`allegations of this paragraph.
`
`37.
`
`38.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`7
`
`Ingenico Inc. v. IOENGINE, LLC
`IPR2019-00879 (US 9,059,969)
`Exhibit 2030
`
`

`

`Case 1:18-cv-00826-GMS Document 12 Filed 08/17/18 Page 8 of 317 PageID #: 181
`
`
`39.
`
`40.
`
`41.
`
`42.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`43.
`
`44.
`
`45.
`
`46.
`
`47.
`
`48.
`
`49.
`
`50.
`
`51.
`
`52.
`
`53.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`54.
`
`55.
`
`56.
`
`57.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`58.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`8
`
`Ingenico Inc. v. IOENGINE, LLC
`IPR2019-00879 (US 9,059,969)
`Exhibit 2030
`
`

`

`Case 1:18-cv-00826-GMS Document 12 Filed 08/17/18 Page 9 of 317 PageID #: 182
`
`
`59.
`
`60.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`61.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`62.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`63.
`
`IOENGINE admits that an actual controversy exists between it and Ingenico as to
`
`infringement of the ’047 Patent. Except as expressly admitted above, IOENGINE denies any
`
`remaining characterizations and allegations of this paragraph.
`
`COUNT II
`(NONINFRINGEMENT OF THE ’969 PATENT)
`
`64.
`
`IOENGINE incorporates by reference this Answer’s responses to Paragraphs 1-63
`
`of the Complaint. Except as expressly admitted above, IOENGINE denies any remaining
`
`characterizations and allegations of Paragraphs 1-63 of the Complaint.
`
`65.
`
`IOENGINE admits that it owns all right, title, and interest in the ’969 Patent,
`
`including the right to assert all causes of action arising under that patent. Except as expressly
`
`admitted, IOENGINE denies the remaining characterizations and allegations of this paragraph.
`
`66.
`
`67.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`68.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`9
`
`Ingenico Inc. v. IOENGINE, LLC
`IPR2019-00879 (US 9,059,969)
`Exhibit 2030
`
`

`

`Case 1:18-cv-00826-GMS Document 12 Filed 08/17/18 Page 10 of 317 PageID #: 183
`
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`69.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`70.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`71.
`
`72.
`
`73.
`
`74.
`
`75.
`
`76.
`
`77.
`
`78.
`
`79.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`80.
`
`81.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`82.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`83.
`
`84.
`
`85.
`
`86.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`10
`
`Ingenico Inc. v. IOENGINE, LLC
`IPR2019-00879 (US 9,059,969)
`Exhibit 2030
`
`

`

`Case 1:18-cv-00826-GMS Document 12 Filed 08/17/18 Page 11 of 317 PageID #: 184
`
`
`87.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`88.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`89.
`
`90.
`
`91.
`
`92.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`93.
`
`IOENGINE admits that the current PayPal Mobile Card Reader, PayPal Chip and
`
`Swipe Reader, and PayPal Chip and Tap Reader products do not infringe claim 23 of the ’969
`
`Patent. Except as expressly admitted, IOENGINE denies the remaining characterizations and
`
`allegations of this paragraph.
`
`94.
`
`95.
`
`96.
`
`97.
`
`98.
`
`99.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`100.
`
`IOENGINE admits that an actual controversy exists between it and Ingenico as to
`
`infringement of the ’969 patent. Except as expressly admitted above, IOENGINE denies any
`
`remaining characterizations and allegations of this paragraph.
`
`11
`
`Ingenico Inc. v. IOENGINE, LLC
`IPR2019-00879 (US 9,059,969)
`Exhibit 2030
`
`

`

`Case 1:18-cv-00826-GMS Document 12 Filed 08/17/18 Page 12 of 317 PageID #: 185
`
`
`COUNT III
`(NONINFRINGEMENT OF THE ’703 PATENT)
`
`101.
`
`IOENGINE incorporates by reference this Answer’s responses to Paragraphs
`
`1-100 of the Complaint. Except as expressly admitted above, IOENGINE denies any remaining
`
`characterizations and allegations of Paragraphs 1-100 of the Complaint.
`
`102.
`
`IOENGINE admits that it owns all right, title, and interest in the ’703 Patent,
`
`including the right to assert all causes of action arising under that patent. Except as expressly
`
`admitted, IOENGINE denies the remaining characterizations and allegations of this paragraph.
`
`103.
`
`104.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`105.
`
`106.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`107.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`108.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`109.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`110.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`111.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`12
`
`Ingenico Inc. v. IOENGINE, LLC
`IPR2019-00879 (US 9,059,969)
`Exhibit 2030
`
`

`

`Case 1:18-cv-00826-GMS Document 12 Filed 08/17/18 Page 13 of 317 PageID #: 186
`
`
`112.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`113.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`114.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`115.
`
`116.
`
`117.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`118.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`119.
`
`120.
`
`121.
`
`122.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`123.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`124.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`125.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`13
`
`Ingenico Inc. v. IOENGINE, LLC
`IPR2019-00879 (US 9,059,969)
`Exhibit 2030
`
`

`

`Case 1:18-cv-00826-GMS Document 12 Filed 08/17/18 Page 14 of 317 PageID #: 187
`
`
`126.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`127.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`128.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`129.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`130.
`
`131.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`132.
`
`133.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`134.
`
`135.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`136.
`
`IOENGINE admits that use of the current PayPal Mobile Card Reader, PayPal
`
`Chip and Swipe Reader, and PayPal Chip and Tap Reader products do not involve executing
`
`program code, on a processor on the PayPal Mobile Card Reader, PayPal Chip and Swipe
`
`Reader, or PayPal Chip and Tap Reader to provide a terminal with biometric data stored in a
`
`PayPal Mobile Card Reader, PayPal Chip and Swipe Reader, or PayPal Chip and Tap Reader’s
`
`14
`
`Ingenico Inc. v. IOENGINE, LLC
`IPR2019-00879 (US 9,059,969)
`Exhibit 2030
`
`

`

`Case 1:18-cv-00826-GMS Document 12 Filed 08/17/18 Page 15 of 317 PageID #: 188
`
`
`memory. Except as expressly admitted, IOENGINE denies the remaining characterizations and
`
`allegations of this paragraph.
`
`137.
`
`138.
`
`IOENGINE denies the characterizations and allegations of this paragraph.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`139.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`140.
`
`IOENGINE admits that no current PayPal Mobile Card Reader, PayPal Chip and
`
`Swipe Reader, or PayPal Chip and Tap Reader is configured to execute program code to provide
`
`a terminal with biometric data. Except as expressly admitted, IOENGINE denies the remaining
`
`characterizations and allegations of this paragraph.
`
`141.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`142.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`143.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`144.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`145.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`146.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`15
`
`Ingenico Inc. v. IOENGINE, LLC
`IPR2019-00879 (US 9,059,969)
`Exhibit 2030
`
`

`

`Case 1:18-cv-00826-GMS Document 12 Filed 08/17/18 Page 16 of 317 PageID #: 189
`
`
`147.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`148.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`149.
`
`IOENGINE admits that the current PayPal Mobile Card Reader, PayPal Chip and
`
`Swipe Reader, and PayPal Chip and Tap Reader products do not infringe claim 9 of the ’703
`
`Patent. Except as expressly admitted, IOENGINE denies the remaining characterizations and
`
`allegations of this paragraph.
`
`150.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`151.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`152.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations this paragraph and thus denies them.
`
`153.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`154.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them
`
`155.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`156.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations this paragraph and thus denies them.
`
`16
`
`Ingenico Inc. v. IOENGINE, LLC
`IPR2019-00879 (US 9,059,969)
`Exhibit 2030
`
`

`

`Case 1:18-cv-00826-GMS Document 12 Filed 08/17/18 Page 17 of 317 PageID #: 190
`
`
`157.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the characterizations and allegations in this paragraph and thus denies them.
`
`158.
`
`IOENGINE lacks knowledge or information sufficient to form a belief about the
`
`truth of the ch