Case 5:19-cv-04809-LHK Document 17 Filed 10/09/19 Page 1 of 25
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`COOLEY LLP
`Heidi Keefe (178960)
`(hkeefe@cooley.com)
`Lowell Mead (223989)
`(lmead@cooley.com)
`Priya B. Viswanath (238089)
`(pviswanath@cooley.com)
`3175 Hanover Street
`Palo Alto, California 94304
`Telephone:
`(650) 843-5000
`Facsimile:
`(650) 849-7400
`COOLEY LLP
`Phillip Morton (Pro Hac Vice)
`(pmorton@cooley.com)
`1299 Pennsylvania Avenue
`NW, Suite 700
`Washington, DC 20004-2400
`Telephone: (202) 842-7800
`Facsimile: (202) 842-7899
`Attorneys for Defendant
`Apple, Inc.
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`
`COREPHOTONICS, LTD.,
`Plaintiff,
`
`v.
`
`APPLE INC.
`
`Defendant.
`
`Case No. 3:19-cv-04809-LHK
`ANSWER TO COMPLAINT FOR
`PATENT INFRINGEMENT
`DEMAND FOR JURY TRIAL
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`ANSWER TO COMPLAINT
`Case No. 3:19-cv-4809-LHK
`
`APPLE V. COREPHOTONICS
`IPR2020-00478
`Exhibit 2005
`Page 1
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`

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`Case 5:19-cv-04809-LHK Document 17 Filed 10/09/19 Page 2 of 25
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`ANSWER
`1.
`Defendant Apple Inc. (“Apple”) answers the Complaint filed by Plaintiff
`Corephotonics, Ltd. (“Corephotonics”). Each Allegation not expressly admitted is denied. The
`following numbered paragraphs of this Answer correspond to the numbered paragraphs in the
`Complaint, other than with respect to affirmative defenses, counterclaims, jury demand set forth
`herein, and the Prayer for Relief.
`NATURE OF THE ACTION
`2.
`Apple admits that this purports to be a civil action for patent infringement under
`35 U.S.C. § 1, et seq.
`3.
`Apple admits that U.S. Patent No. 9,661,233 (the “’233 patent”) is entitled “Dual
`Aperture Zoom Digital Camera.” Apple further admits that the face of the ’233 patent indicates
`that it issued on May 23, 2017. Apple further admits that the face of the ’233 patent indicates
`that Corephotonics was the assignee of the patent on the date of issuance, but Apple is without
`sufficient information to admit or deny whether Corephotonics is the legal owner of the ’233
`patent. Apple further admits that Exhibit A is a copy of the ’233 patent. Except as expressly
`admitted, Apple denies the remaining allegations in paragraph 3.
`4.
`Apple admits that U.S. Patent No. 10,230,898 (the “’898 patent”) is entitled “Dual
`Aperture Zoom Camera with Video Support and Switching / Non-Switching Dynamic Control.”
`Apple further admits that the face of the ’898 patent indicates that it issued on March 12, 2019.
`Apple further admits that the face of the ’898 patent indicates that Corephotonics was the
`assignee of the patent on the date of issuance, but Apple is without sufficient information to
`admit or deny whether Corephotonics is the legal owner of the ’898 patent. Apple further admits
`that Exhibit B is a copy of the ’898 patent. Except as expressly admitted, Apple denies the
`remaining allegations in paragraph 4.
`5.
`Apple admits that U.S. Patent No. 10,288,840 (the “’840 patent”) is entitled
`“Miniature Telephoto Lens Module and A Camera Utilizing Such a Lens Module.” Apple
`further admits that the face of the ’840 patent indicates that it issued on May 14, 2019. Apple
`further admits that the face of the ’840 patent indicates that Corephotonics was the assignee of
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`ANSWER TO COMPLAINT
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`APPLE V. COREPHOTONICS
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`Exhibit 2005
`Page 2
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`the patent on the date of issuance, but Apple is without sufficient information to admit or deny
`whether Corephotonics is the legal owner of the ’840 patent. Apple further admits that Exhibit C
`is a copy of the ’840 patent. Except as expressly admitted, Apple denies the remaining
`allegations in paragraph 5.
`6.
`Apple admits that U.S. Patent No. 10,317,647 (the “’647 patent”) is entitled
`“Miniature Telephoto Lens Module Assembly.” Apple further admits that the face of the ’647
`patent indicates that it issued on June 11, 2019. Apple further admits that the face of the ’647
`patent indicates that Corephotonics was the assignee of the patent on the date of issuance, but
`Apple is without sufficient information to admit or deny whether Corephotonics is the legal
`owner of the ’647 patent. Apple further admits that Exhibit D is a copy of the ’647 patent.
`Except as expressly admitted, Apple denies the remaining allegations in paragraph 6.
`7.
`Apple admits that U.S. Patent No. 10,324,277 (the “’277 patent”) is entitled
`“Miniature Telephoto Lens Assembly.” Apple further admits that the face of the ’277 patent
`indicates that it issued on June 18, 2019. Apple further admits that the face of the ’277 patent
`indicates that Corephotonics was the assignee of the patent on the date of issuance, but Apple is
`without sufficient information to admit or deny whether Corephotonics is the legal owner of the
`’277 patent. Apple further admits that Exhibit E is a copy of the ’277 patent. Except as
`expressly admitted, Apple denies the remaining allegations in paragraph 7.
`8.
`Apple admits that U.S. Patent No. 10,330,897 (the “’897 patent”) is entitled
`“Miniature Telephoto Lens Assembly.” Apple further admits that the face of the ’897 patent
`indicates that it issued on June 25, 2019. Apple further admits that the face of the ’897 patent
`indicates that Corephotonics was the assignee of the patent on the date of issuance, but Apple is
`without sufficient information to admit or deny whether Corephotonics is the legal owner of the
`’897 patent. Apple further admits that Exhibit F is a copy of the ’897 patent and a certificate of
`correction dated July 23, 2019. Except as expressly admitted, Apple denies the remaining
`allegations in paragraph 8.
`9.
`Apple admits that U.S. Patent No. 10,225,479 (the “’479 patent”) is entitled “Dual
`Aperture Zoom Digital Camera.” Apple further admits that the face of the ’479 patent indicates
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`that it issued on March 5, 2019. Apple further admits that the face of the ’479 patent indicates
`that Corephotonics was the assignee of the patent on the date of issuance, but Apple is without
`sufficient information to admit or deny whether Corephotonics is the legal owner of the ’479
`patent. Apple further admits that Exhibit G is a copy of the ’479 patent. Except as expressly
`admitted, Apple denies the remaining allegations in paragraph 9.
`10.
`Apple admits that U.S. Patent No. 10,015,408 (the “’408 patent”) is entitled “Dual
`Aperture Zoom Digital Camera.” Apple further admits that the face of the ’408 patent indicates
`that it issued on July 3, 2018. Apple further admits that the face of the ’408 patent indicates that
`Corephotonics was the assignee of the patent on the date of issuance, but Apple is without
`sufficient information to admit or deny whether Corephotonics is the legal owner of the ’408
`patent. Apple further admits that Exhibit H is a copy of the ’408 patent. Except as expressly
`admitted, Apple denies the remaining allegations in paragraph 10.
`11.
`Apple admits that U.S. Patent No. 10,356,332 (the “’332 patent”) is entitled “Dual
`Aperture Zoom Camera With Video Support And Switching / Non-Switching Dynamic Control.”
`Apple further admits that the face of the ’332 patent indicates that it issued on July 16, 2019.
`Apple further admits that the face of the ’332 patent indicates that Corephotonics was the
`assignee of the patent on the date of issuance, but Apple is without sufficient information to
`admit or deny whether Corephotonics is the legal owner of the ’332 patent. Apple further admits
`that Exhibit I is a copy of the ’332 patent. Except as expressly admitted, Apple denies the
`remaining allegations in paragraph 11.
`12.
`Apple admits that U.S. Patent No. 10,326,942 (the “’942 patent”) is entitled “Dual
`Aperture Zoom Digital Camera.” Apple further admits that the face of the ’942 patent indicates
`that it issued on July 16, 2019. Apple further admits that the face of the ’942 patent indicates
`that Corephotonics was the assignee of the patent on the date of issuance, but Apple is without
`sufficient information to admit or deny whether Corephotonics is the legal owner of the ’942
`patent. Apple further admits that Exhibit J is a copy of the ’942 patent. Except as expressly
`admitted, Apple denies the remaining allegations in paragraph 12.
`13.
`Apple denies the allegations in paragraph 13.
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`ANSWER TO COMPLAINT
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`APPLE V. COREPHOTONICS
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`Exhibit 2005
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`Case 5:19-cv-04809-LHK Document 17 Filed 10/09/19 Page 5 of 25
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`THE PARTIES
`14.
`Apple is without sufficient information to admit or deny the allegations in
`paragraph 14 and therefore denies them.
`15.
`Apple admits that it is a corporation organized and existing under the laws of the
`state of California. Apple denies that its principal place of business is 1 Infinite Loop,
`Cupertino, California. Apple’s principal place of business is One Apple Park, Cupertino,
`California.
`
`JURISDICTION AND VENUE
`16.
`Apple admits that based on the allegations in the First Amended Complaint, this
`Court would appear to have subject matter jurisdiction over this action pursuant to 28 U.S.C. §§
`1331 and 1338(a).
`17.
`Apple admits that it is subject to this Court’s personal jurisdiction for purposes of
`this action. Apple admits that it resides in and has its principal place of business in the Northern
`District of California. Apple denies that it has committed any acts of patent infringement. Apple
`admits that it has sold and offered for sale Apple products and services in the Northern District
`of California. Except as expressly admitted, Apple denies the remaining allegations in
`paragraph 17.
`18.
`Apple admits that venue is proper in the Northern District of California for the
`purposes of this action. Apple admits that it resides and has a place of business in this District.
`Apple denies that it has committed any acts of patent infringement. Except as expressly
`admitted, Apple denies the remaining allegations in paragraph 18.
`INTRADISTRICT ASSIGNMENT
`19.
`Apple admits that Civil L.R. 3-2(c) states that cases involving “Intellectual
`Property Rights” are assigned on a district-wide basis. Except as expressly admitted, Apply
`denies the remaining allegations in paragraph 19.
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`ANSWER TO COMPLAINT
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`APPLE V. COREPHOTONICS
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`Exhibit 2005
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`Case 5:19-cv-04809-LHK Document 17 Filed 10/09/19 Page 6 of 25
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`FACTUAL ALLEGATIONS
`
`A.
`Corephotonics’ Alleged Dual Camera Technology
`20.
`Apple is without sufficient information to admit or deny the allegations in
`paragraph 20 and therefore denies them.
`21.
`Apple is without sufficient information to admit or deny the allegations in
`paragraph 21 and therefore denies them.
`22.
`Apple is without sufficient information to admit or deny the allegations in
`paragraph 22 and therefore denies them.
`23.
`Apple is without sufficient information to admit or deny the allegations in
`paragraph 23 and therefore denies them.
`24.
`Apple admits that certain United States patents on their faces state that the
`assignee of the patent on the date of issuance is Corephotonics, including the ’408, ’479, ’898,
`’840, ’647, ’277, ’942, ’897, ’332, and ’233 patents (collectively, the “Asserted Patents”), but
`Apple is without sufficient information to admit or deny whether Corephotonics is the legal
`owner of the Asserted Patents. Apple is without sufficient information to admit or deny the
`remaining allegations in paragraph 24 and therefore denies them.
`25.
`Apple admits that the website cited in Footnote 1 contains the first quotation
`listed in paragraph 25. Apple is without sufficient information to admit or deny the remaining
`allegations on paragraph 25 and therefore denies them.
`26.
`Apple is without sufficient information to admit or deny the allegations in
`paragraph 26 and therefore denies them.
`27.
`Apple denies that any Apple products “employ” Corephotonics’ “designs” and
`that any of Corephotonics’ purported “designs” are “innovative.” Apple is without sufficient
`information to admit or denythe allegations related to Corephotonics’s unspecified “intellectual
`property rights,” and on that basis Apple denies the allegation that it acted “without any regard
`to” any such “intellectual property rights.” Apply denies the remaining allegations in paragraph
`27.
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`Exhibit 2005
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`Case 5:19-cv-04809-LHK Document 17 Filed 10/09/19 Page 7 of 25
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`B.
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`Apple’s Alleged Interest in Corephotonics’ Technology and Intellectual
`Property
`28.
`Apple admits that Apple personnel had discussions with Corephotonics personnel.
`Apple is without sufficient information to admit or deny the remaining allegations in
`paragraph 28 and therefore denies them.
`29.
`Apple admits that Apple personnel attended meetings with Corephotonics
`personnel to discuss a potential business arrangement. Apple is without sufficient information to
`admit or deny the remaining allegations in paragraph 29 and therefore denies them.
`30.
`Apple admits that Apple personnel attended meetings with Corephotonics
`personnel to discuss a potential business arrangement. Apple is without sufficient information to
`admit or deny the remaining allegations in paragraph 30 and therefore denies them.
`31.
`Apple admits that Apple personnel attended meetings with Corephotonics
`personnel to discuss a potential business arrangement. Apple is without sufficient information to
`admit or deny the remaining allegations in paragraph 31 and therefore denies them.
`32.
`Apple is without sufficient information to admit or deny the allegations in
`paragraph 32 and therefore denies them.
`33.
`Apple is without sufficient information to admit or deny the allegations in
`paragraph 33 and therefore denies them.
`34.
`Apple is without sufficient information to admit or deny the allegations in
`paragraph 34 and therefore denies them.
`35.
`Apple admits that Apple personnel attended meetings with Corephotonics
`personnel to discuss a potential business arrangement. Apple is without sufficient information to
`admit or deny the remaining allegations in paragraph 35 and therefore denies them.
`36.
`Apple admits that Apple personnel attended meetings with Corephotonics
`personnel to discuss a potential business arrangement. Apple is without sufficient information to
`admit or deny the remaining allegations in paragraph 36 and therefore denies them.
`37.
`Apple is without sufficient information to admit or deny the allegations in
`paragraph 37 and therefore denies them.
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`Case 5:19-cv-04809-LHK Document 17 Filed 10/09/19 Page 8 of 25
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`38.
`Apple admits that an article dated November 18, 2014 at the cited website
`discusses alleged rumors about Apple’s camera technology. Apple denies that the article was
`“suggesting that it would be similar to the dual camera technology that Corephotonics had
`developed and presented earlier that year, and which Corephotonics had been discussing over
`this period with Apple.” Apple is without sufficient information to admit or deny the remaining
`allegations in paragraph 38 and therefore denies them.
`39.
`Apple admits that Apple personnel attended meetings with Corephotonics
`personnel to discuss a potential business arrangement. Apple is without sufficient information to
`admit or deny the remaining allegations in paragraph 39 and therefore denies them.
`40.
`Apple admits that Apple personnel attended meetings with Corephotonics
`personnel to discuss a potential business arrangement. Apple is without sufficient information to
`admit or deny the remaining allegations in paragraph 40 and therefore denies them.
`41.
`Apple admits that it announced the iPhone 7 Plus on September 7, 2016. Apple
`admits that the iPhone 7 Plus included a dual camera configuration. Apple further admits that
`the iPhone 7 Plus included a telephoto lens. Apple denies that “a rear dual camera assembly
`including a telephoto camera for enhanced zoom” is “one of Corephotonics’ core innovative
`concepts.”
` Apple denies that “[t]he hardware specifications and important software
`functionalities were similar to what Corephotonics had shown and demonstrated to Apple.”
`Apple is without sufficient information to admit or deny the remaining allegations in paragraph
`41 and therefore denies them.
`42.
`Apple admits that Apple personnel attended meetings with Corephotonics
`personnel to discuss a potential business arrangement. Apple is without sufficient information to
`admit or deny the allegations in paragraph 42 and therefore denies them.
`43.
`Apple admits that Apple personnel attended meetings with Corephotonics
`personnel to discuss a potential business arrangement. Apple is without sufficient information to
`admit or deny the remaining allegations in paragraph 43 and therefore denies them.
`44.
`Apple admits that Corephotonics sent an email on or about October 31, 2017
`alleging that the iPhone 7 Plus and iPhone 8 Plus allegedly infringed Corephotonics’ patents, but
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`the email provided no information supporting Corephotonics allegations. Apple denies the
`allegation that Apple did not respond to Corephotonics’ October 31, 2017 email. Except as
`expressly admitted, Apple denies the remaining allegations in paragraph 44.
`45.
`Apple admits that Corephotonics filed a Complaint in Corephotonics, Ltd. v.
`Apple Inc., Case No. 5:17-cv-06457-LHK (“Corephotonics I”) on November 6, 2017 (the
`“Corephotonics I Complaint”) and that case is pending before the Honorable Judge Lucy Koh.
`Apple admits that the Corephotonics I Complaint alleged that the iPhone 7 Plus infringed the
`’032, ’712, ’291, and ’152 patents. Apple admits that Corephotonics I is administratively stayed
`pending resolution of inter partes review (“IPR”) proceeding initiated by Apple against
`Corephotonics’ patents. Except as expressly admitted, Apple denies the remaining allegations in
`paragraph 45.
`46.
`Apple admits that it received a letter in April 2018 from Corephotonics alleging
`that it had examined Apple’s iPhone 7 Plus, iPhone 8 Plus, and iPhone X and believed that those
`products infringed U.S. Patent No. 9,857,568 (the “’568 patent”) and claims set forth in U.S.
`Patent Application 15/424,853 (the “’853 application”). Apple further admits that the ’853
`application is a continuation of the ’291 patent. Apple denies Corephotonics’ allegations of
`infringement of the ’568 patent or ’853 application. Except as expressly admitted, Apple denies
`the remaining allegations in paragraph 46.
`47.
`Apple admits that on April 25, 2018 it responded to Corephotonics April 2018
`letter. Apple further admits that its April 25, 2018 correspondence stated that Corephotonics had
`failed to articulate any detail for its claim relating to the ’568 patent and ’853 application.
`Except as expressly admitted, Apple denies the remaining allegations in paragraph 47.
`48.
`Apple admits that Corephotonics filed a second complaint on April 30, 2018
`alleging that Apple’s iPhone 7 Plus, iPhone 8 Plus, and iPhone X infringe the ’712 and ’568
`patents. Apple admits that the case in which Corephotonics filed the second complaint is
`pending before Judge Koh as Case No. 5:18-cv-02555-LHK. Apple further admits that Case No.
`5:18-cv-02555-LHK
`is administratively stayed pending
`the resolution of related IPR
`proceedings. Except as expressly admitted, Apple denies the remaining allegations in
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`Case 5:19-cv-04809-LHK Document 17 Filed 10/09/19 Page 10 of 25
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`paragraph 48.
`49.
`Apple admits that Corephotonics wrote to Apple on July 26, 2018. Apple further
`admits that Corephotonics’ July 26, 2018 correspondence stated that the ’853 application had
`been issued as the ’408 patent. Apple further admits that Corephotonics July 26, 2018
`correspondence stated that Corephotonics believed that the iPhone X infringed the claims of the
`’408 patent. Apple denies Corephotonics’ allegation of infringement of the ’408 patent. Except
`as expressly admitted, Apple denies the remaining allegations in paragraph 49.
`50.
`Apple admits that on August 8, 2018 it responded to Corephotonics’ July 26,
`2018 correspondence. Apple admits that correspondence noted that Corephotonics had failed to
`provide sufficient information regarding the ’408 patent, and that Corephotonics’ failure had
`“impede[d] Apple’s investigation into [Corephotonics’] allegations.” Except as expressly
`admitted, Apple denies the remaining allegations in paragraph 50.
`51.
`Apple admits that Corephotonics wrote to Apple on November 30, 2018. Apple
`further admits that Corephotonics November 30, 2018 correspondence alleged that Apple
`infringed claims of U.S. Patent Application Nos. 15/540,676 (“the ’676 application”),
`15/817,235 (the “’235 application”), 15/976,391 (the “’391 application”), and 15, 976,422 (the
`“’422 application”). Apple denies Corephotonics’ allegations of infringement of the claims of
`the ’676, ’235, ’391, and ’422 applications. Apple admits that charts were attached to the
`November 30, 2018 correspondence. Apple denies that the attached charts describe infringement
`of any patent claims. Except as expressly admitted, Apple denies the remaining allegations in
`paragraph 51.
`52.
`Apple admits that the face of the ’840 patent indicates that it issued from the ’676
`application. Apple admits that the face of the ’277 patent indicates that it issued from the ’235
`application. Apple admits that the face of the ’897 patent indicates that it issued from the ’391
`application. Apple admits that the face of the ’647 patent indicates that it issued from the ’422
`application. Apple admits that the face of the ’898 patent indicates that it issued from U.S.
`Patent Application 15,324,720 (“the ’720 application”). Except as expressly admitted, Apple
`denies the remaining allegations in paragraph 52.
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`53.
`Apple admits that the face of U.S. Patent Application 16/048,242 indicates that it
`is a continuation of the ’291 and ’408 patents, and that the face of the ’479 patent indicates that it
`issued from that patent application. Apple is without sufficient information to admit or deny the
`allegations in paragraph 53 and therefore denies them.
`
`C.
`
`Apple’s Alleged Analysis of Corephotonics’ Patents and Patent Applications
`During Apple’s Pursuit of its Own Patents
`54.
`Apple admits that it sought patent protection for its own inventions. Apple does
`not understand Corephotonics’ allegation that “During this time, Corephotonics’ patents and
`related patent applications were significant in the art,” and therefore denies the allegation. Apple
`is without sufficient information to admit or deny the remaining allegations in paragraph 54 and
`therefore denies them.
`55.
`Apple admits that it filed U.S. Patent Application No. 14/069/027 (the “’027
`application”). Apple admits that the ’027 application later issued as U.S. Patent No. 9,223,118.
`Apple admits that an office action was issued dated February 18, 2015 rejecting the pending
`claims in the ’027 application based on U.S. Pat. App. Pub. No. 2015/0029601A1 (the “Dror
`application”). Apple admits that certain patents in this case and in the two previously filed
`actions claim priority to the Dror application. Apple admits that Romeo Mercado is a named
`inventor on the ’027 application. Apple admits that Romeo Mercado was employed by Apple at
`the time of the introduction of the iPhone 7 Plus. Apple is without sufficient information to
`admit or deny the remaining allegations in paragraph 55 and therefore denies them.
`56.
`Corephotonics does not identify which two references it alleges are disclosed on
`the earliest IDS for the ’720 application. Accordingly, Apple is without sufficient information to
`admit or deny this allegation. Apple admits that it disclosed the Dror application as prior art to
`its ’720 application in its March 24, 2016 IDS filing. Corephotonics does not identify which
`application it is referring to when it uses the short form “’716 application” and “’136
`application.” Therefore, Apple is without sufficient information to admit or deny whether it
`disclosed the Dror application as prior art to the “’716 application” or the “’136 application.”
`Apple admits that the ’291 patent is cited on the face of U.S. Patent Nos. 9,769,389; 9,774,787;
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`ANSWER TO COMPLAINT
`Case No. 3:19-cv-4809-LHK
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`IPR2020-00478
`Exhibit 2005
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`Case 5:19-cv-04809-LHK Document 17 Filed 10/09/19 Page 12 of 25
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`9,781,345; 10,063,783; 10,122,931; 10,136,048; and 10,264,188. Apple admits that it has
`numerous patents assigned to it. Corephotonics does not identify which patents it is referencing
`as “numerous recently-issued patents assigned to Apple,” so Apple is without sufficient
`information to admit or deny Corephotonics’ allegations about any such patents and therefore
`denies them. Except as expressly admitted, Apple denies the remaining allegations in paragraph
`56.
`
`57.
`Apple is without sufficient information to admit or deny the allegations in
`paragraph 57 and therefore denies them.
`FIRST CAUSE OF ACTION
`Alleged Infringement of Patent No. 9,661,233
`Apple incorporates its responses to the foregoing paragraphs as though fully set
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`58.
`forth herein.
`59.
`Apple denies the allegations in paragraph 59.
`60.
`Apple denies that it infringes any valid claim of the ’233 patent and therefore
`denies the allegations in paragraph 60.
`61.
`Apple denies that it has infringed or continues to infringe the ’233 patent. Apple
`denies that any alleged infringement of the ’233 patent has been or continues to be wanton,
`deliberate, egregious, and willful. In view of the lack of specificity in the remaining allegations
`in paragraph 61, Apple is without sufficient information to admit or deny the remaining
`allegations in paragraph 61 and therefore denies them.
`62.
`Apple admits that Corephotonics alleges that Apple infringes claims of patents on
`the face of which Dror or Shabtay is a named inventor. Apple is without sufficient information
`to admit or deny the remaining allegations in paragraph 62, and therefore denies them.
`63.
`Apple admits that it learned of the ’233 patent after the issue date on the face of
`the ’233 patent. Apple denies the remaining allegations in paragraph 63.
`64.
`Apple denies the allegations in paragraph 64.
`65.
`Apple denies the allegations in paragraph 65.
`66.
`Apple denies the allegations in paragraph 66.
`11
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`ANSWER TO COMPLAINT
`Case No. 3:19-cv-4809-LHK
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`APPLE V. COREPHOTONICS
`IPR2020-00478
`Exhibit 2005
`Page 12
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`

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`Case 5:19-cv-04809-LHK Document 17 Filed 10/09/19 Page 13 of 25
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`67.
`Apple denies the allegations in paragraph 67.
`68.
`Apple admits that it discussed the benefits of the telephoto lens functionality in
`7
`Plus
`in
`the
`video
`available
`at
`the
`following URL:
`iPhone
`the
`https://www.youtube.com/watch?v=NS0txu_Kzl8. As of the date of this Answer, no video is
`available at the following URL: https://www.youtube.com/watch?v=Q6dsRpVyyWs; therefore,
`Apple is without sufficient information to admit or deny the allegation relating to this URL.
`Apple denies the remaining allegations in paragraph 68
`69.
`Apple denies the allegations in paragraph 69.
`70.
`Apple denies the allegations in paragraph 70.
`71.
`Apple denies the allegations in paragraph 71
`SECOND CAUSE OF ACTION
`Alleged Infringement of Patent No. 10,230,898
`Apple incorporates its responses to the foregoing paragraphs as though fully set
`
`72.
`forth herein.
`73.
`Apple denies the allegations in paragraph 73.
`74.
`Apple denies that it infringes any valid claim of the ’898 patent and therefore
`denies the allegations in paragraph 74.
`75.
`Apple denies that it has infringed or continues to infringe the ’898 patent. Apple
`denies that any alleged infringement of the ’898 patent has been or continues to be wanton,
`deliberate, egregious, and willful. In view of the lack of specificity in the remaining allegations
`in paragraph 75, Apple is without sufficient information to admit or deny the remaining
`allegations in paragraph 75 and therefore denies them.
`76.
`Apple admits that Corephotonics has alleged infringement of multiple patents in
`its pending litigations in this District . Apple admits that Corephotonics’ November 30, 2018
`correspondence alleged that Apple would allegedly infringe allowed claims of the ’720
`application. Apple is without sufficient information to admit or deny the remaining allegations
`in paragraph 76, and therefore denies them.
`77.
`Apple admits that it learned of the ’898 patent after the issue date on the face of
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`ANSWER TO COMPLAINT
`Case No. 3:19-cv-4809-LHK
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`APPLE V. COREPHOTONICS
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`Exhibit 2005
`Page 13
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`Case 5:19-cv-04809-LHK Document 17 Filed 10/09/19 Page 14 of 25
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`the ’898 patent. Apple denies the remaining allegations in paragraph 77.
`78.
`Apple admits that Corephotonics has filed two Complaints in this District alleging
`that Apple infringes Corephotonics’ patents. Apple denies the remaining allegations in
`paragraph 78.
`79.
`Apple denies the allegations in paragraph 79.
`80.
`Apple denies the allegations in paragraph 80.
`81.
`Apple denies the allegations in paragraph 81.
`82.
`Apple denies the allegations in paragraph 82.
`83.
`Apple admits that it publishes information about and provides instructions to end
`users about the telephoto lens functionality in the iPhone 7 Plus, iPhone 8 Plus and iPhone X.
`Apple further admits that it discussed the telephoto lens functionality of the iPhone X at the
`website: https://www.apple.com/iphone-x/. Apple further admits that it discusses the telephoto
`lens
`functionality of
`the
`iPhone 7 Plus and
`iPhone 8 Plus at
`the websites:
`https://www.apple.com/iphone-7/specs/ and https://www.apple.com/iphone-8/specs/.
` Apple
`further admits that video tutorials about photography with Apple iPhone products are available,
`including a video
`titled “How
`to compose with
`telephoto camera” available at:
`https://www.apple.com/iphone/photography-how-to/. Apple further admits that it discussed the
`benefits of the telephoto lens functionality in the iPhone 7 Plus in the video available at the
`following URL: https://www.youtube.com/watch?v=NS0txu_Kzl8. As of the date of this
`Answer,
`no
`video
`is
`available
`at
`the
`following
`URL:
`https://www.youtube.com/watch?v=Q6dsRpVyyWs; therefore, Apple is without sufficient
`information to admit or deny the allegation relating to this URL. Apple denies the remaining
`allegations in paragraph 83.
`84.
`Apple denies the allegations in paragraph 84.
`85.
`Apple den