Case 6:20-cv-00090-ADA Document 27 Filed 04/01/20 Page 1 of 51
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`C.A. No. 6:20-CV-00090
`JURY TRIAL REQUESTED
`
`HUAWEI TECHNOLOGIES CO., LTD.,
`HUAWEI DEVICE CO., LTD., and
`HUAWEI DIGITAL TECHNOLOGIES
`(CHENGDU) CO., LTD.
`Plaintiffs,
`
`v.
`VERIZON COMMUNICATIONS, INC.,
`CELLCO PARTNERSHIP D/B/A VERIZON
`WIRELESS, and VERIZON BUSINESS
`NETWORK SERVICES, INC.
`Defendants.
`VERIZON BUSINESS NETWORK
`SERVICES, INC., and CELLCO
`PARTNERSHIP D/B/A VERIZON
`WIRELESS, INC.,
`
`Counterclaim-Plaintiffs,
`
`v.
`
`HUAWEI TECHNOLOGIES CO., LTD.,
`HUAWEI DEVICE CO., LTD., and
`HUAWEI DIGITAL TECHNOLOGIES
`(CHENGDU) CO., LTD.
`
`Counterclaim-Defendants.
`
`VERIZON’S ANSWER, AFFIRMATIVE DEFENSES, AND COUNTERCLAIMS TO
`HUAWEI’S COMPLAINT
`
`1
`
`HUAWEI 2008
`VERIZON V. HUAWEI
`IPR2020-01141
`
`

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`Case 6:20-cv-00090-ADA Document 27 Filed 04/01/20 Page 2 of 51
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`Defendants Verizon Communications Inc.,1 Cellco Partnership d/b/a Verizon Wireless,
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`and Verizon Business Network Services, Inc. (collectively, “Verizon”), by their undersigned
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`attorneys, hereby answer Plaintiffs Huawei Technologies Co., Ltd., Huawei Device Co., Ltd.,
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`And Huawei Digital Technologies (Chengdu) Co., Ltd.’s (collectively, “Huawei”) Complaint for
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`Patent Infringement.
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`Verizon is one of America’s most innovative companies, and a key portion of America’s
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`telecommunications infrastructure. Verizon offers industry-leading connectivity to its
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`customers, connecting millions of people, companies and communities through its award-
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`winning networks. RootMetrics, the United States’ most rigorous and scientific network tester,
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`ranked Verizon highest in overall network performance for a record-setting 13 consecutive years.
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`For 12 consecutive years, J.D. Power awarded Verizon top honors in numerous wireless network
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`performance categories. And Forbes ranked Verizon in the top 20 of its 2020 list of companies
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`“doing right by America.”
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`Much as it has led the way in 4G LTE network reliability and speeds, it is innovating in
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`5G network technology. Verizon holds over seven thousand United States patents for its
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`inventions. Verizon’s patented ideas fuel Verizon’s networks—not the outdated and valueless
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`techniques referenced in Huawei’s complaint.
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`Huawei has a long record of failing to play by the rules where intellectual property is
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`concerned (as exemplified by the behavior set forth in its recent indictment by the United States
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`government for intellectual property theft, among other crimes). Huawei’s suit against Verizon
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`is another example of an attempt by Huawei to take credit for American innovation. Huawei
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`1 Verizon Communications Inc. is purely a stockholding entity not capable of acts of patent
`infringement and thus not a proper defendant in this litigation. Verizon Communications Inc.
`specifically denies that personal jurisdiction exists over it.
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`2
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`ignores Verizon’s and its suppliers’ own substantial investment in research and development.
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`Verizon will vigorously defend against Huawei’s baseless claims of patent infringement.
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`As set forth below, Verizon denies that it has infringed any valid and enforceable
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`intellectual property rights, including the asserted claims of U.S. Patent Nos. 7,965,709 (“the
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`’709 Patent”), 8,154,986 (“the ’986 Patent”), 10,027,693 (“the ’693 Patent”), 7,609,288 (“the
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`’288 Patent”), 9,521,366 (“the ’366 Patent”), 7,715,832 (“the ’832 Patent”), and 8,761,839 (“the
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`’839 Patent”) (collectively, the “Asserted Patents”). Verizon further denies that any patent
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`claims in this action are valid or enforceable. Verizon further reserves the right to amend or
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`supplement its Answer based on any additional facts or developments that become available or
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`that arise after the filing of this Answer. Verizon denies each and every allegation averred in the
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`Complaint that is not expressly admitted below. Any factual allegation admitted below is
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`admitted only as to the specific admitted facts, and not as to any purported conclusions,
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`characterizations, implications, or speculations that might follow from the admitted facts.
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`SPECIFIC RESPONSES TO ALLEGATIONS IN THE COMPLAINT
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`Except as expressly admitted below, Verizon denies each and every allegation set forth in
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`the Complaint.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`THE PARTIES
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`1.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 1 and therefore denies them.
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`2.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 2 and therefore denies them.
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`3
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`3.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 3 and therefore denies them.
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`4.
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`Verizon admits Verizon Communications Inc. is a corporation organized and
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`existing under the laws of Delaware, with a principal place of business at 1095 Avenue of the
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`Americas, New York, New York 10036 and admits Verizon Communications Inc. may be served
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`through its registered agent The Corporation Trust Company, Corporation Trust Center, 1209
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`Orange Street, Wilmington, Delaware 19801.
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`5.
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`Verizon admits Cellco Partnership d/b/a Verizon Wireless is a general partnership
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`organized and existing under the laws of Delaware, with a principal place of business at One
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`Verizon Way, Basking Ridge, New Jersey 07920 and admits Cellco Partnership is an indirect
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`wholly-owned subsidiary of Verizon Communications Inc., and together with Verizon
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`Communications Inc. is collectively referred to as “Verizon Wireless” and admits Verizon
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`Wireless may be served through its registered The Corporation Trust Company, Corporation
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`Trust Center, 1209 Orange Street, Wilmington, Delaware 19801.
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`6.
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`Verizon admits Verizon Business Network Services Inc. (“Verizon Business”) is
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`a Delaware corporation with a principal place of business at at One Verizon Way, Basking
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`Ridge, New Jersey 07920 and admits Verizon Business may be served through its registered
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`agent for service of process in Texas at CT Corporation System, 1999 Bryan St., Suite 900,
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`Dallas, Texas 75201.
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`JURISDICTION AND VENUE
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`7.
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`Verizon admits the Complaint purports to bring an action under the patent laws of
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`the United States, Title 35 of the United States Code, in particular 35 U.S.C. § 1, et seq. but
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`denies that Verizon has committed any acts of infringement. To the extent the allegations
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`4
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`contained in paragraph 7 call for a legal conclusion, no response is required. To the extent a
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`response is required, the allegations contained in paragraph 7 are denied.
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`8.
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`Verizon admits that the Asserted Patents are the patents-at-issue but denies that it
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`has committed or induced any acts of infringement of the Asserted Patents.
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`9.
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`To the extent the allegations contained in paragraph 9 call for a legal conclusion,
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`no response is required. To the extent a response is required, Verizon admits that this Court has
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`personal jurisdiction over all defendants identified in the Complaint other than Verizon
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`Communications for purposes of this action only and that it conducts and has conducted business
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`in the State of Texas and in the Western District of Texas including through stores and/or
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`authorized retailers and other locations and that its website provides a coverage map that
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`identifies where it provides coverage for its 4G LTE branded network, including locations within
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`this federal judicial district. Verizon denies that it has committed or induced any acts of
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`infringement of the Asserted Patents in the United States, in Texas, or in this federal judicial
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`district. Except as expressly admitted, the allegations contained in paragraph 9 are denied.
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`10.
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`To the extent the allegations contained in paragraph 10 call for a legal conclusion,
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`no response is required. To the extent a response is required, for purposes of this action only,
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`Verizon admits that venue in the Western District of Texas is proper under 28 U.S.C. §§ 1391(b)
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`and (c) and 1400(b). Except as expressly admitted, the allegations contained in paragraph 10 are
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`denied.
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`HUAWEI’S INNOVATION AND RESEARCH
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`11.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 11 and therefore denies them.
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`5
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`12.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 12 and therefore denies them.
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`13.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 13 and therefore denies them.
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`14.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 14 and therefore denies them.
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`15.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 15 and therefore denies them.
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`16.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 16 and therefore denies them.
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`17.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 17 and therefore denies them.
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`18.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 18 and therefore denies them.
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`19.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 19 and therefore denies them.
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`20.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 20 and therefore denies them.
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`21.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 21 and therefore denies them.
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`22.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 22 and therefore denies them.
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`6
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`23.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 23 and therefore denies them.
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`24.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 24 and therefore denies them.
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`25.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 25 and therefore denies them.
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`26.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 26 and therefore denies them.
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`VERIZON’S USE OF HUAWEI’S INNOVATIONS
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`27.
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`28.
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`Denied.
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`Verizon denies that it has committed, induced, or contributed to any acts of
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`infringement of the Asserted Patents in the United States, in Texas, or in this federal judicial
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`district. Verizon, however, admits that its 2019 Annual Report states, “Enterprise Solutions
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`offers traditional circuit-based network services, and advanced networking solutions including
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`Private IP, Ethernet, and Software-Defined Wide Area Network, along with our traditional voice
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`services and advanced workforce productivity and customer contact center solutions.” Except as
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`expressly admitted, the allegations contained in paragraph 28 are denied.
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`29.
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`30.
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`31.
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`Denied.
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`Denied.
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`Verizon denies that it has committed, induced, or contributed to any acts of
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`infringement of the Asserted Patents in the United States, in Texas, or in this federal judicial
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`district. Verizon, however, admits that its 2019 Annual Report states, “Total Wireline segment
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`operating revenues for the year ended December 31, 2018 totaled $29.8 billion . . . In 2018,
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`Enterprise Solutions revenues were $8.8 billion, representing approximately 30% of Wireline’s
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`aggregate revenues.” Except as expressly admitted, the allegations contained in paragraph 31 are
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`denied.
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`LICENSING NEGOTIATIONS
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`32.
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`Verizon denies that it has committed, induced, or contributed to any acts of
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`infringement of the Asserted Patents in the United States, in Texas, or in this federal judicial
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`district. Verizon, however, admits that Huawei contacted Verizon on February 7, 2019. Except
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`as expressly admitted, the allegations contained in paragraph 32 are denied.
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`33.
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`Verizon denies that the communication from Huawei put Verizon on notice of any
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`Asserted Patent.
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`34.
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`Verizon denies that it has committed or induced any acts of infringement of the
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`Asserted Patents in the United States, in Texas, or in this federal judicial district. Verizon,
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`however, admits that it met with Huawei on March 28, 2019. Except as expressly admitted, the
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`allegations contained in paragraph 32 are denied.
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`35.
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`Verizon admits that Huawei provided claim charts relating to the Asserted
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`Patents, with the exception of the ’839 Patent, on March 28, 2019.
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`36.
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`Verizon denies that the meeting with Huawei put Verizon on notice of any
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`Asserted Patent.
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`37.
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`Verizon admits that it met with Huawei representatives on June 4 and June 5,
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`2019 to discuss claim charts concerning a wide variety of technologies.
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`38.
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`Verizon admits that it spoke with Huawei representatives by telephone on June
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`18, 2019. Except as expressly admitted, the allegations contained in paragraph 38 are denied.
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`8
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`39.
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`Verizon admits that it met with Huawei on July 30 and July 31, 2019, September
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`3 and September 4, 2019, and November 21 and November 22, 2019 in New York. Except as
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`expressly admitted, the allegations contained in paragraph 39 are denied.
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`40.
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`Verizon admits it met with Huawei on January 21, 2020. Except as expressly
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`admitted, the allegations contained in paragraph 40 are denied.
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`41.
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`Denied.
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`COUNT I: INFRINGEMENT OF PATENT NO. 7,965,709
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`42.
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`Verizon repeats its responses to each preceding paragraph as if fully set forth
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`herein.
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`43.
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`Verizon admits that the face of the ’709 Patent states that the patent issued on
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`June 21, 2011 and contains the title “Bridge Forwarding Method and Apparatus.” Verizon
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`admits that Exhibit A of the Complaint purports to be a copy of the ’709 patent. Except as
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`expressly admitted, the allegations contained in paragraph 43 are denied.
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`44.
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`45.
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`Denied.
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`Verizon admits that the face of the ’709 Patent includes the quoted language and
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`figure. Except as expressly admitted, the allegations contained in paragraph 45 are denied.
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`46.
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`Verizon admits that the face of the ’709 Patent includes the quoted language.
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`Except as expressly admitted, the allegations contained in paragraph 46 are denied.
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`47.
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`Verizon admits that the face of the ’709 Patent includes the quoted language.
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`Except as expressly admitted, the allegations contained in paragraph 47 are denied.
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`48.
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`Verizon admits that the face of the ’709 Patent includes the quoted language.
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`Except as expressly admitted, the allegations contained in paragraph 48 are denied.
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`9
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`49.
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`Verizon admits that the face of the ’709 Patent includes the quoted language.
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`Except as expressly admitted, the allegations contained in paragraph 49 are denied.
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`50.
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`Verizon admits that the face of the ’709 Patent includes the quoted language.
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`Except as expressly admitted, the allegations contained in paragraph 50 are denied.
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`51.
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`To the extent that paragraph 51 of the Complaint sets forth conclusions of law, no
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`response is required. To the extent a response is required, Verizon denies the allegations of
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`paragraph 51 of the Complaint.
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`52.
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`To the extent that paragraph 52 of the Complaint sets forth conclusions of law, no
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`response is required. To the extent a response is required, Verizon denies the allegations of
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`paragraph 52 of the Complaint.
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`53.
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`To the extent that paragraph 53 of the Complaint sets forth conclusions of law, no
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`response is required. To the extent a response is required, Verizon denies the allegations of
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`paragraph 53 of the Complaint. Verizon has moved to dismiss Huawei’s allegations of indirect
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`infringement.
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`54.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 54 and therefore denies them.
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`55.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 55 and therefore denies them.
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`56.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 56 and therefore denies them.
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`57.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 57 and therefore denies them.
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`10
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`58.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 58 and therefore denies them
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`59.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 59 and therefore denies them.
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`60.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 60 and therefore denies them.
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`61.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 61 and therefore denies them.
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`62.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 62 and therefore denies them.
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`63.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 63 and therefore denies them.
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`64.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 64 and therefore denies them.
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`65.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 65 and therefore denies them.
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`66.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 66 and therefore denies them.
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`67.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 67 and therefore denies them.
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`68.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 68 and therefore denies them.
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`69.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 69 and therefore denies them.
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`70.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 70 and therefore denies them.
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`71.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 71 and therefore denies them.
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`72.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 72 and therefore denies them.
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`73.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 73 and therefore denies them.
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`74.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 74 and therefore denies them.
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`75.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 75 and therefore denies them.
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`Denied.
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`Denied. Verizon has moved to dismiss Huawei’s allegations of indirect
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`76.
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`77.
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`infringement.
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`78.
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`Denied. Verizon has moved to dismiss Huawei’s allegations of indirect
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`infringement.
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`79.
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`Denied. Verizon has moved to dismiss Huawei’s allegations of indirect
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`infringement.
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`80.
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`Denied. Verizon has moved to dismiss Huawei’s allegations of indirect
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`infringement.
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`81.
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`82.
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`83.
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`Denied.
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`Denied.
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`Denied.
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`COUNT II: INFRINGEMENT OF PATENT NO. 8,154,986
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`84.
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`Verizon repeats its responses to each preceding paragraph as if fully set forth
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`
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`herein.
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`85.
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`Verizon admits that the face of the ’986 Patent states that the patent issued on
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`April 10, 2012 and contains the title “Method for Fast Converging End-To-End Services and
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`Provider Edge Equipment Thereof.” Verizon admits that Exhibit B of the Complaint purports to
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`be a copy of the ’986 patent. Except as expressly admitted, the allegations contained in
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`paragraph 85 are denied.
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`86.
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`To the extent that paragraph 86 of the Complaint sets forth conclusions of law, no
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`response is required. To the extent a response is required, Verizon denies the allegations of
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`paragraph 86 of the Complaint.
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`87.
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`Verizon admits that the face of the ’986 Patent includes the quoted language and
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`figure. Except as expressly admitted, the allegations contained in paragraph 87 are denied.
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`88.
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`Verizon admits that the face of the ’986 Patent includes the quoted language.
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`Except as expressly admitted, the allegations contained in paragraph 88 are denied.
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`89.
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`Verizon admits that the face of the ’986 Patent includes the quoted language.
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`Except as expressly admitted, the allegations contained in paragraph 89 are denied.
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`90.
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`Verizon admits that the face of the ’986 Patent includes the quoted language.
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`Except as expressly admitted, the allegations contained in paragraph 90 are denied.
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`91.
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`Denied.
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`92.
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`Verizon admits that the face of the ’986 Patent includes the quoted language.
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`Except as expressly admitted, the allegations contained in paragraph 92 are denied.
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`93.
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`To the extent that paragraph 93 of the Complaint sets forth conclusions of law, no
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`response is required. To the extent a response is required, Verizon denies the allegations of
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`paragraph 93 of the Complaint.
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`94.
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`Denied. Verizon has moved to dismiss Huawei’s allegations of indirect
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`infringement.
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`95.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 95 and therefore denies them.
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`96.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 96 and therefore denies them.
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`97.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 97 and therefore denies them.
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`98.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 98 and therefore denies them.
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`99.
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`Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 99 and therefore denies them.
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`100. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 100 and therefore denies them.
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`101. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 101 and therefore denies them.
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`102. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 102 and therefore denies them.
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`103. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 103 and therefore denies them.
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`104. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 104 and therefore denies them.
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`105. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 105 and therefore denies them.
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`106. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 106 and therefore denies them.
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`107. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 107 and therefore denies them.
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`108. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 108 and therefore denies them.
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`109. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 109 and therefore denies them.
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`110. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 110 and therefore denies them.
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`111. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 111 and therefore denies them.
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`112. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 112 and therefore denies them.
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`113. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 113 and therefore denies them.
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`114. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 114 and therefore denies them.
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`115. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 115 and therefore denies them.
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`116. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 116 and therefore denies them.
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`117. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 117 and therefore denies them.
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`118. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 118 and therefore denies them.
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`119. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 119 and therefore denies them.
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`120. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 120 and therefore denies them.
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`121. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 121 and therefore denies them.
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`122. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 122 and therefore denies them.
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`123. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 123 and therefore denies them.
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`124. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 124 and therefore denies them.
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`125. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 125 and therefore denies them.
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`126. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 126 and therefore denies them.
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`127. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 127 and therefore denies them.
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`128. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 128 and therefore denies them.
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`129. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 129 and therefore denies them.
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`130. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 130 and therefore denies them.
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`131. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 131 and therefore denies them.
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`132. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 132 and therefore denies them.
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`133. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 133 and therefore denies them.
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`134. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 134 and therefore denies them.
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`135. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 135 and therefore denies them.
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`136. Verizon is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations of paragraph 136 and therefore denies them.
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`137. Denied.
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`138. Denied. Verizon has moved to dismiss Huawei’s allegations of indirect
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`infringement.
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`139. Denied. Verizon has moved to dismiss Huawei’s allegations of indirect
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`infringement.
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`140. Denied. Verizon has moved to dismiss Huawei’s allegations of indirect
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`infringement.
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`141. Denied. Verizon has moved to dismiss Huawei’s allegations of indirect
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`infringement.
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`142. Denied. Verizon has moved to dismiss Huawei’s allegations of indirect
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`infringement.
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`143. Denied.
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`144. Denied.
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`145. Denied.
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`COUNT III: INFRINGEMENT OF PATENT NO. 10,027,693
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`146. Verizon repeats its responses to each preceding paragraph as if fully set forth
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`herein.
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`147. Verizon admits that the face of the ’693 Patent states that the patent issued on July
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`17, 2018 and contains the title “Method, Device and System for Alerting against Unknown
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`Malicious Codes within a Network Environment.” Verizon admits that Exhibit C of the
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`Complaint purports to be a copy of the ’693 patent. Except as expressly admitted, the allegations
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`contained in paragraph 147 are denied.
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`148. To the extent that paragraph 148 of the Complaint sets forth conclusions of law,
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`no response is required. To the extent a response is required, Verizon denies the allegations of
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`paragraph 148 of the Complaint.
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`149. To the extent that paragraph 149 of the Complaint sets forth conclusions of law,
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`no response is required. To the extent a response is required, Verizon denies the allegations of
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`paragraph 149 of the Complaint.
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`150. To the extent that paragraph 150 of the Complaint sets forth conclusions of law,
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`no response is required. To the extent a response is required, Verizon denies the allegations of
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`paragraph 150 of the Complaint.
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`151. Verizon admits that the face of the ’693 Patent includes the quoted language.
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`Except as expressly admitted, the allegations contained in paragraph 151 are denied.
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`152. To the extent that paragraph 152 of the Complaint sets forth conclusions of law,
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`no response is required. To the extent a response is required, Verizon denies the allegations of
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`paragraph 152 of the Complaint.
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`153. To the extent that paragraph 153 of the Complaint sets forth conclusions of law,
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`no response