throbber
Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 1 of 55 PageID #: 196
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF DELAWARE
`
`
`MONTEREY RESEARCH, LLC,
`
`
`
`
`Plaintiff,
`
`v.
`
`
`
`
`QUALCOMM INCORPORATED,
`QUALCOMM TECHNOLOGIES,
`INC., and QUALCOMM CDMA
`TECHNOLOGIES ASIA-PACIFIC
`PTE LTD.,
`
`
`
`
`
`)
`)
`)
`)
`) C.A. No. 19-2083-CFC
`)
`JURY TRIAL DEMANDED
`
`)))
`
`))
`
`
`
`
`)
`)
`Defendants.
`
`
`
`
`
`
`QUALCOMM INCORPORATED, QUALCOMM
`TECHNOLOGIES, INC. AND QUALCOMM
`CDMA TECHNOLOGIES ASIA-PACIFIC PTE LTD.’S
`ANSWER, COUNTERCLAIMS AND DEFENSES TO THE COMPLAINT
`
`
`
`
`
`Defendants Qualcomm Incorporated, Qualcomm Technologies, Inc., and
`
`Qualcomm CDMA Technologies Asia-Pacific Pte Ltd. (collectively, “Qualcomm”)
`
`answer the November 1, 2019 Complaint of Plaintiff Monterey Research, LLC
`
`(“Monterey”) by and through undersigned counsel. Qualcomm further asserts its
`
`defenses and counterclaims.
`
`Qualcomm denies that it has infringed any valid and enforceable patent rights
`
`at issue in this action. Qualcomm further denies that any patent claims asserted
`
`against Qualcomm in this action are valid or enforceable. Qualcomm further denies
`
`any liability to Plaintiff, or that Plaintiff has suffered any legally cognizable damage
`1
`
`
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0001
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 2 of 55 PageID #: 197
`
`for which Qualcomm is responsible. The responses below reflect the current status
`
`of Qualcomm’s knowledge and belief regarding the subject matter of the allegations
`
`to which they respond. Qualcomm reserves the right to supplement, modify, and/or
`
`amend its responses, defenses, and counterclaims based on any additional facts or
`
`developments that become available or that arise after the filing of this Answer.
`
`Except as expressly admitted below, Qualcomm denies each and every
`
`allegation averred in the Complaint, including without limitation the headings, sub-
`
`headings, and diagrams contained in the Complaint. Any factual allegation admitted
`
`below is admitted as to only the specific admitted facts, and not as to any purported
`
`conclusions, characterizations, implications, or speculations that might follow from
`
`the admitted facts. Qualcomm responds to the numbered paragraphs of the
`
`Complaint as follows. The paragraph numbering in these responses corresponds to
`
`the numbered paragraphs in the Complaint.
`
`Subject to the foregoing, Qualcomm states as follows:
`
`INTRODUCTION
`
`Qualcomm is currently without knowledge or information sufficient to
`
`1.
`
`form a belief as to the truth of the allegations and characterization in Paragraph 1 of
`
`the Complaint, and therefore denies them.
`
`2.
`
`Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 2 of the Complaint.
`
`
`
`
`2
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0002
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 3 of 55 PageID #: 198
`
`NATURE OF THE CASE
`
`3.
`
`Qualcomm admits that Plaintiff has filed a civil action against
`
`Qualcomm purporting to assert claims for infringement of U.S. Patent Nos.
`
`6,534,805 (“the ’805 patent”); 6,642,573 (“the ’573 patent”); 6,651,134 (“the ’134
`
`patent”); 6,680,516 (“the ’516 patent”); 6,765,407 (“the ’407 patent”); 7,092,281
`
`(“the ’281 patent”); 7,572,727 (“the ’727 patent”); and 7,977,797 (“the ’797 patent”)
`
`(collectively, “the Patents-in-Suit”). Qualcomm denies that Plaintiff’s claims have
`
`merit and expressly denies that it has infringed any valid claim of any patent asserted
`
`in the Complaint.
`
`THE PARTIES
`
`4.
`
`Qualcomm is currently without knowledge or information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 4 of the Complaint, and therefore denies them.
`
`5.
`
`Qualcomm admits that Qualcomm Incorporated is a corporation
`
`organized and existing under the laws of the State of Delaware, having a principal
`
`place of business at 5775 Morehouse Drive, San Diego, CA 92121. Qualcomm
`
`admits that Qualcomm Incorporated is a publicly-traded company and is the parent
`
`corporation of Qualcomm Technologies, Inc. (“QTI”), and admits that Qualcomm
`
`CDMA Technologies Asia-Pacific Pte Ltd (“QCTAP”) is a wholly-owned subsidiary
`
`of Qualcomm Global Trading Pte Ltd., a corporation organized and existing under
`
`the laws of Singapore, which is itself a wholly-owned subsidiary of QTI. Qualcomm
`3
`
`
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0003
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 4 of 55 PageID #: 199
`
`denies the remaining allegations and characterizations contained in Paragraph 5 of
`
`the Complaint
`
`6.
`
`Qualcomm admits that QTI is a wholly-owned subsidiary of Qualcomm
`
`Incorporated, and further admits that QTI is a corporation organized and existing
`
`under the laws of the State of Delaware, having a principal place of business at 5775
`
`Morehouse Drive, San Diego, CA 92121. Qualcomm denies the remaining
`
`allegations and characterizations in Paragraph 6 of the Complaint.
`
`7.
`
`Qualcomm admits that QCTAP is a wholly-owned subsidiary of
`
`Qualcomm Global Trading Pte Ltd., a corporation organized and existing under the
`
`laws of Singapore, which is itself a wholly-owned subsidiary of QTI, and admits that
`
`QCTAP is a corporation organized and existing under the laws of Singapore, having
`
`a principal place of business at 6 Serangood North Avenue 5, #03-04, Singapore
`
`554910, Singapore.
`
` Qualcomm denies
`
`the
`
`remaining allegations and
`
`characterizations in Paragraph 7 of the Complaint.
`
`8.
`
`Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 8 of the Complaint.
`
`JURISDICTION AND VENUE
`
`9.
`
`Qualcomm admits that this Court has subject matter jurisdiction over
`
`patent infringement actions under 28 U.S.C. §§ 1331 and 1338(a), provided that
`
`standing and other requirements are met. Qualcomm denies any remaining
`
`allegations and characterizations in Paragraph 9 of the Complaint.
`4
`
`
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0004
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 5 of 55 PageID #: 200
`
`10. Paragraph 10 alleges legal conclusions to which no response is required.
`
`To the extent a response is required, Qualcomm does not contest that this Court has
`
`personal jurisdiction over Qualcomm Inc. and QTI. Qualcomm denies the remaining
`
`allegations and characterizations in Paragraph 10 of the Complaint.
`
`11. Paragraph 11 alleges legal conclusions regarding personal jurisdiction
`
`to which no response is required. Qualcomm admits that Qualcomm Inc. and QTI
`
`are corporation organized and existing under the laws of the State of Delaware.
`
`Qualcomm denies the remaining allegations and characterizations in Paragraph 11 of
`
`the Complaint.
`
`12. Paragraph 12 alleges legal conclusions regarding personal jurisdiction
`
`to which no response is required. Qualcomm denies the remaining allegations and
`
`characterizations in Paragraph 12 of the Complaint. Specifically, Qualcomm denies
`
`that QCTAP has committed, aided, abetted, contributed to and/or participated in the
`
`commission of any acts purportedly giving rise to this action within the State of
`
`Delaware, denies that QCTAP has transacted and conducted business in the State of
`
`Delaware and with Delaware residents with respect to products accused of infringing
`
`the Patents-in-Suit, and denies that QCTAP, directly or through intermediaries, uses,
`
`sells, ships, distributes, imports into, offers for sale, and/or advertises or otherwise
`
`promotes products in the United States.
`
`13. Paragraph 13 alleges legal conclusions to which no response is required.
`
`To the extent a response is required, Qualcomm does not contest that venue is proper
`5
`
`
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0005
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 6 of 55 PageID #: 201
`
`in this Court with respect to Qualcomm Inc. and QTI. Qualcomm denies the
`
`remaining allegations and characterizations in Paragraph 13 of the Complaint.
`
`THE PATENTS-IN-SUIT
`
`14. Qualcomm incorporates by reference its responses to the allegations
`
`contained in paragraphs 1-13 of the complaint. To the extent an additional response
`
`is required, Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 14 of the Complaint.
`
`A. U.S. Patent No. 6,534,805
`
`15. Qualcomm admits that U.S. Patent No. 6,534,805 (“the ‘805 patent”) is
`
`titled “SRAM cell design,” and was issued by the United States Patent and
`
`Trademark Office on March 18, 2003. Qualcomm acknowledges that Exhibit A to
`
`the Complaint purports to be a copy of the ‘805 patent and an Ex Parte
`
`Reexamination Certificate. Qualcomm denies the remaining allegations and
`
`characterizations in Paragraph 15 of the Complaint.
`
`16. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 16 of the Complaint, and therefore denies them.
`
`B. U.S. Patent No. 6,642,573
`
`17. Qualcomm admits that U.S. Patent No. 6,642,573 (“the ‘573 patent”) is
`
`titled “Use of high-K dielectric material
`
`in modified ONO structure for
`
`semiconductor devices” and was issued by the United States Patent and Trademark
`6
`
`
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0006
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 7 of 55 PageID #: 202
`
`Office on November 4, 2003. Qualcomm acknowledges that Exhibit B to the
`
`Complaint purports to be a copy of the ‘573 patent. Qualcomm denies the remaining
`
`allegations and characterizations in Paragraph 17 of the Complaint.
`
`18. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 18 of the Complaint, and therefore denies them.
`
`C. U.S. Patent No. 6,651,134
`
`19. Qualcomm admits that U.S. Patent No. 6,651,134 (“the ‘134 patent”) is
`
`titled “Memory device with fixed length non interruptible burst” and was issued by
`
`the United States Patent and Trademark Office on November 18, 2003. Qualcomm
`
`acknowledges that Exhibit C to the Complaint purports to be a copy of the ‘134
`
`patent. Qualcomm denies the remaining allegations and characterizations in
`
`Paragraph 19 of the Complaint.
`
`20. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 20 of the Complaint, and therefore denies them.
`
`D. U.S. Patent No. 6,680,516
`
`21. Qualcomm admits that U.S. Patent No. 6,680,516 (“the ‘516 patent”) is
`
`titled “Controlled thickness gate stack” and was issued by the United States Patent
`
`and Trademark Office on January 20, 2004. Qualcomm acknowledges that Exhibit
`
`D to the Complaint purports to be a copy of the ‘516 patent and a Certificate of
`7
`
`
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0007
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 8 of 55 PageID #: 203
`
`Correction. Qualcomm denies the remaining allegations and characterizations in
`
`Paragraph 21 of the Complaint.
`
`22. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 22 of the Complaint, and therefore denies them.
`
`E. U.S. Patent No. 6,765,407
`
`23. Qualcomm admits that U.S. Patent No. 6,765,407 (“the ‘407 patent”) is
`
`titled “Digital configurable macro architecture” and was issued by the United States
`
`Patent and Trademark Office on July 20, 2004. Qualcomm acknowledges that
`
`Exhibit E to the Complaint purports to be a copy of the ‘407 patent. Qualcomm
`
`denies the remaining allegations and characterizations in Paragraph 23 of the
`
`Complaint.
`
`24. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 24 of the Complaint, and therefore denies them.
`
`F. U.S. Patent No. 7,092,281
`
`25. Qualcomm admits that U.S. Patent No. 7,092,281 (“the ‘281 patent”) is
`
`titled “Method and apparatus for reducing soft error rate in SRAM arrays using
`
`elevated SRAM voltage during periods of low activity” and was issued by the United
`
`States Patent and Trademark Office on August 15, 2006. Qualcomm acknowledges
`
`that Exhibit F to the Complaint purports to be a copy of the ‘281 patent. Qualcomm
`8
`
`
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0008
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 9 of 55 PageID #: 204
`
`denies the remaining allegations and characterizations in Paragraph 25 of the
`
`Complaint.
`
`26. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 26 of the Complaint, and therefore denies them.
`
`G. U.S. Patent No. 7,572,727
`
`27. Qualcomm admits that U.S. Patent No. 7,572,727 (“the ‘727 patent”) is
`
`titled “Semiconductor formation method that utilizes multiple etch stop layers” and
`
`was issued by the United States Patent and Trademark Office on August 11, 2009.
`
`Qualcomm acknowledges that Exhibit G to the Complaint purports to be a copy of
`
`the ‘727 patent. Qualcomm denies the remaining allegations and characterizations in
`
`Paragraph 27 of the Complaint.
`
`28. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 28 of the Complaint, and therefore denies them.
`
`H. U.S. Patent No. 7,977,797
`
`29. Qualcomm admits that U.S. Patent No. 7,977,797 (“the ‘797 patent”) is
`
`titled “Integrated circuit with contact region and multiple etch stop insulation layer”
`
`and was issued by the United States Patent and Trademark Office on July 12, 2011.
`
`Qualcomm acknowledges that Exhibit H to the Complaint purports to be a copy of
`
`the ‘797 patent. Qualcomm denies the remaining allegations and characterizations in
`9
`
`
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0009
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 10 of 55 PageID #: 205
`
`Paragraph 29 of the Complaint.
`
`30. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 30 of the Complaint, and therefore denies them.
`
`FACTUAL BACKGROUND
`
`31. Qualcomm incorporates by reference its responses to the allegations
`
`contained in paragraphs 1-30 of the complaint. To the extent an additional response
`
`is required, Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 31 of the Complaint.
`
`32. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 32 of the Complaint, and therefore denies them.
`
`33. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 33 of the Complaint.
`
`34. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 34 of the Complaint.
`
`35. Qualcomm admits that material is available (as of January 7, 2020) at
`
`www.qualcomm.com.
`
` Qualcomm denies
`
`the
`
`remaining allegations and
`
`characterizations contained in Paragraph 35 of the Complaint.
`
`
`
`
`
`
`
`10
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0010
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 11 of 55 PageID #: 206
`
`QUALCOMM’S PRE-SUIT KNOWLEDGE OF
`MONTEREY’S PATENTS AND CHARGE OF
`INFRINGEMENT
`
`36. Qualcomm admits
`
`that, before filing
`
`this Complaint, IPValue
`
`
`
`Management, Inc. identified certain patents to Qualcomm Inc. and alleged that
`
`certain Qualcomm Inc. products infringed some of those patents. Qualcomm further
`
`admits that IPValue Management, Inc. requested that Qualcomm Inc. license
`
`Monterey’s patent portfolio before filing this Complaint. Qualcomm denies the
`
`remaining allegations and characterizations in Paragraph 36 of the Complaint.
`
`a.
`
`Qualcomm admits that a letter bearing a date of January 31, 2018
`
`was received, to which was attached a table listing the ’516, ’805, ’407, ’727, and
`
`’797 patents. Qualcomm admits that the letter dated January 31, 2018 stated that
`
`Monterey “believes that Qualcomm requires a license from Monterey” and that it
`
`alleged that “Qualcomm and its customers therefore infringe these patents.”
`
`Qualcomm denies the remaining allegations and characterizations contained in
`
`Paragraph 36(a) of the Complaint.
`
`b.
`
`Qualcomm admits that, during a May 14, 2018 meeting, IPValue
`
`presented what it purported was an introduction to the Monterey patent portfolio.
`
`Qualcomm denies the remaining allegations and characterizations contained in
`
`Paragraph 36(b) of the Complaint.
`
`c.
`
`Qualcomm admits that an in-person meeting occurred on July 17,
`
`2018. Qualcomm denies the remaining allegations and characterizations in
`11
`
`
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0011
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 12 of 55 PageID #: 207
`
`Paragraph 36(c) of the Complaint.
`
`d.
`
`Qualcomm is currently without knowledge of information
`
`sufficient to form a belief as to the truth of the allegations and characterizations
`
`contained in Paragraph 36(d) of the Complaint, and therefore denies them.
`
`e.
`
`Qualcomm admits that an in-person meeting occurred on October
`
`9, 2018. Qualcomm denies the remaining allegations and characterizations in
`
`Paragraph 36(e) of the Complaint.
`
`f.
`
`Qualcomm is currently without knowledge of information
`
`sufficient to form a belief as to the truth of the allegations and characterizations
`
`contained in Paragraph 30(f) of the Complaint, and therefore denies them.
`
`g.
`
`Qualcomm is currently without knowledge of information
`
`sufficient to form a belief as to the truth of the allegations and characterizations
`
`contained in Paragraph 36(g) of the Complaint, and therefore denies them.
`
`h.
`
`Qualcomm admits that, during a November 13, 2018 meeting,
`
`IPValue offered to license the Monterey patent portfolio to Qualcomm Inc.
`
`Qualcomm denies the remaining allegations and characterizations in Paragraph 36(h)
`
`of the Complaint.
`
`i.
`
`Qualcomm denies the allegations and characterizations contained
`
`in Paragraph 36(i) of the Complaint.
`
`j.
`
`Qualcomm denies the allegations and characterizations contained
`
`in Paragraph 36(j) of the Complaint.
`
`
`
`12
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0012
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 13 of 55 PageID #: 208
`
`37. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 37 of the Complaint.
`
`COUNT ONE
`INFRINGEMENT OF THE ’805 PATENT
`
`38. Qualcomm incorporates by reference its responses to the allegations
`
`contained in paragraphs 1-37 of the complaint. To the extent an additional response
`
`is required, Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 38 of the Complaint.
`
`39. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 39 of the Complaint, and therefore denies them.
`
`40. Qualcomm denies that the ‘805 patent is valid and enforceable.
`
`41. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 41 of the Complaint, and therefore denies them.
`
`42. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 42 of the Complaint, and therefore denies them.
`
`43. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 43 of the Complaint.
`
`44. Qualcomm admits that some of its products include SRAM with a six-
`
`
`
`13
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0013
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 14 of 55 PageID #: 209
`
`transistor or eight-transistor cell design. Qualcomm denies the remaining allegations
`
`and characterizations contained in Paragraph 44 of the Complaint.
`
`45. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 45 of the Complaint.
`
`46. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 46 of the Complaint.
`
`a.
`
`Qualcomm denies the allegations and characterizations contained
`
`in Paragraph 46(a) of the Complaint.
`
`b.
`
`Qualcomm denies the allegations and characterizations contained
`
`in Paragraph 46(b) of the Complaint.
`
`47. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 47 of the Complaint.
`
`48. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 48 of the Complaint.
`
`49. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 49 of the Complaint.
`
`50. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 50 of the Complaint.
`
`51. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 51 of the Complaint.
`
`52. Qualcomm denies the allegations and characterizations contained in
`14
`
`
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0014
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 15 of 55 PageID #: 210
`
`Paragraph 52 of the Complaint.
`
`COUNT TWO
`INFRINGEMENT OF THE ’573 PATENT
`
`53. Qualcomm incorporates by reference its responses to the allegations
`
`
`
`contained in paragraphs 1-52 of the complaint. To the extent an additional response
`
`is required, Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 53 of the Complaint.
`
`54.
`
` Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 54 of the Complaint, and therefore denies them.
`
`55. Qualcomm denies that the ‘573 patent is valid and enforceable.
`
`56. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 56 of the Complaint, and therefore denies them.
`
`57. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 57 of the Complaint, and therefore denies them.
`
`58. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 58 of the Complaint.
`
`59. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 59 of the Complaint.
`
`
`
`15
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0015
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 16 of 55 PageID #: 211
`
`60. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 60 of the Complaint.
`
`a.
`
`Qualcomm denies the allegations and characterizations contained
`
`in Paragraph 60(a) of the Complaint.
`
`b.
`
`Qualcomm denies the allegations and characterizations contained
`
`in Paragraph 60(b) of the Complaint.
`
`61. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 61 of the Complaint.
`
`62. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 62 of the Complaint.
`
`63. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 63 of the Complaint.
`
`64. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 64 of the Complaint.
`
`65. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 65 of the Complaint.
`
`66. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 66 of the Complaint.
`
`COUNT THREE
`INFRINGEMENT OF THE ’134 PATENT
`
`67. Qualcomm incorporates by reference its responses to the allegations
`
`16
`
`
`
`
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0016
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 17 of 55 PageID #: 212
`
`contained in paragraphs 1-66 of the complaint. To the extent an additional response
`
`is required, Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 67 of the Complaint.
`
`68. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 68 of the Complaint, and therefore denies them.
`
`69. Qualcomm denies that the ‘134 patent is valid and enforceable.
`
`70. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 70 of the Complaint, and therefore denies them.
`
`71. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 71 of the Complaint, and therefore denies them.
`
`72. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 72 of the Complaint.
`
`73. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 73 of the Complaint.
`
`74. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 74 of the Complaint.
`
`75. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 75 of the Complaint.
`
`
`
`17
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0017
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 18 of 55 PageID #: 213
`
`a.
`
`Qualcomm denies the allegations and characterizations contained
`
`in Paragraph 75(a) of the Complaint.
`
`b.
`
`Qualcomm denies the allegations and characterizations contained
`
`in Paragraph 75(b) of the Complaint.
`
`c.
`
`Qualcomm denies the allegations and characterizations contained
`
`in Paragraph 75(c) of the Complaint.
`
`d.
`
`Qualcomm denies the allegations and characterizations contained
`
`in Paragraph 75(d) of the Complaint.
`
`76. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 76 of the Complaint.
`
`77. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 77 of the Complaint.
`
`78. Qualcomm admits that material is available (as of January 7, 2020) at
`
`https://www.qualcomm.com/media/documents/files/snapdragon-600e-embedded-
`
`platform-product-brief.pdf. Qualcomm denies the remaining allegations and
`
`characterizations contained in Paragraph 78 of the Complaint.
`
`79. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 79 of the Complaint.
`
`80. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 80 of the Complaint.
`
`81. Qualcomm denies the allegations and characterizations contained in
`18
`
`
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0018
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 19 of 55 PageID #: 214
`
`Paragraph 81 of the Complaint.
`
`COUNT FOUR
`INFRINGEMENT OF THE ’516 PATENT
`
`82. Qualcomm incorporates by reference its responses to the allegations
`
`contained in paragraphs 1-81 of the complaint. To the extent an additional response
`
`is required, Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 82 of the Complaint.
`
`83. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 83 of the Complaint, and therefore denies them.
`
`84. Qualcomm denies that the ‘516 patent is valid and enforceable.
`
`85. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 85 of the Complaint, and therefore denies them.
`
`86. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 86 of the Complaint, and therefore denies them.
`
`87. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 87 of the Complaint.
`
`88. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 88 of the Complaint.
`
`
`
`19
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0019
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 20 of 55 PageID #: 215
`
`89. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 89 of the Complaint.
`
`90. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 90 of the Complaint.
`
`a.
`
`Qualcomm denies the allegations and characterizations contained
`
`in Paragraph 90(a) of the Complaint.
`
`b.
`
`Qualcomm denies the allegations and characterizations contained
`
`in Paragraph 90(b) of the Complaint.
`
`c.
`
`Qualcomm denies the allegations and characterizations contained
`
`in Paragraph 90(c) of the Complaint.
`
`d.
`
`Qualcomm denies the allegations and characterizations contained
`
`in Paragraph 90(d) of the Complaint.
`
`91. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 91 of the Complaint.
`
`92. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 92 of the Complaint.
`
`93. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 93 of the Complaint.
`
`94. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 94 of the Complaint.
`
`95. Qualcomm denies the allegations and characterizations contained in
`20
`
`
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0020
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 21 of 55 PageID #: 216
`
`Paragraph 95 of the Complaint.
`
`96. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 79 of the Complaint.
`
`COUNT FIVE
`INFRINGEMENT OF THE ’407 PATENT
`
`97. Qualcomm incorporates by reference its responses to the allegations
`
`contained in paragraphs 1-96 of the complaint. To the extent an additional response
`
`is required, Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 97 of the Complaint.
`
`98. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 98 of the Complaint, and therefore denies them.
`
`99. Qualcomm denies that the ‘407 patent is valid and enforceable.
`
`100. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 100 of the Complaint, and therefore denies them.
`
`101. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 101 of the Complaint, and therefore denies them.
`
`102. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 102 of the Complaint.
`
`
`
`21
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0021
`
`

`

`Case 1:19-cv-02083-CFC Document 11 Filed 01/24/20 Page 22 of 55 PageID #: 217
`
`103. Qualcomm admits that certain of its products include an ARM core.
`
`Qualcomm denies the remaining allegations and characterizations contained in
`
`Paragraph 103 of the Complaint.
`
`104. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 104 of the Complaint.
`
`105. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 105 of the Complaint.
`
`a.
`
`Qualcomm denies the allegations and characterizations contained
`
`in Paragraph 105(a) of the Complaint.
`
`b.
`
`Qualcomm denies the allegations and characterizations contained
`
`in Paragraph 105(b) of the Complaint.
`
`c.
`
`Qualcomm denies the allegations and characterizations contained
`
`in Paragraph 105(c) of the Complaint.
`
`106. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 106 of the Complaint.
`
`107. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 107 of the Complaint.
`
`108. Qualcomm admits that material is available (as of January 7, 2020) at
`
`www.qualcomm.com/products/snapdragon-processors-810
`
`and
`
`at
`
`www.qualcomm.com/system/
`
`files/document/files/snapdragon_produc

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket