Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 1 of 60 PageID #: 440
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF DELAWARE
`
`
`MONTEREY RESEARCH, LLC,
`
`
`
`
`Plaintiff,
`
`v.
`
`
`
`)
`)
`)
`)
`) C.A. No. 19-2083-CFC
`)
`JURY TRIAL DEMANDED
`
`)))
`
`))
`
`
`
`
`QUALCOMM INCORPORATED,
`QUALCOMM TECHNOLOGIES,
`INC., and QUALCOMM CDMA
`TECHNOLOGIES ASIA-PACIFIC
`
`PTE LTD.,
`)
`
`)
`Defendants.
`
`
`
`
`
`
`
`
`
`QUALCOMM INCORPORATED, QUALCOMM TECHNOLOGIES, INC.
`AND QUALCOMM CDMA TECHNOLOGIES ASIA-PACIFIC PTE
`LTD.’S ANSWER, COUNTERCLAIMS AND DEFENSES
`TO THE FIRST AMENDED COMPLAINT
`
`
`
`
`
`Defendants Qualcomm Incorporated, Qualcomm Technologies, Inc., and
`
`
`
`Qualcomm CDMA Technologies Asia-Pacific Pte Ltd.
`
`(collectively,
`
`“Qualcomm”) answer the February 14, 2020 First Amended 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
`
`
`
`1
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0001
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF DELAWARE
`
`
`MONTEREY RESEARCH, LLC,
`
`
`
`
`Plaintiff,
`
`v.
`
`
`
`)
`)
`)
`)
`) C.A. No. 19-2083-CFC
`)
`JURY TRIAL DEMANDED
`
`)))
`
`))
`
`
`
`
`QUALCOMM INCORPORATED,
`QUALCOMM TECHNOLOGIES,
`INC., and QUALCOMM CDMA
`TECHNOLOGIES ASIA-PACIFIC
`
`PTE LTD.,
`)
`
`)
`Defendants.
`
`
`
`
`
`
`
`
`
`QUALCOMM INCORPORATED, QUALCOMM TECHNOLOGIES, INC.
`AND QUALCOMM CDMA TECHNOLOGIES ASIA-PACIFIC PTE
`LTD.’S ANSWER, COUNTERCLAIMS AND DEFENSES
`TO THE FIRST AMENDED COMPLAINT
`
`
`
`
`
`Defendants Qualcomm Incorporated, Qualcomm Technologies, Inc., and
`
`
`
`Qualcomm CDMA Technologies Asia-Pacific Pte Ltd.
`
`(collectively,
`
`“Qualcomm”) answer the February 14, 2020 First Amended 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
`
`
`
`1
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0001
`
`
`
`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 2 of 60 PageID #: 441
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`further denies any liability to Plaintiff, or that Plaintiff has suffered any legally
`
`cognizable damage 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 First Amended Complaint, including without limitation
`
`the headings, sub- headings, and diagrams contained in the First Amended
`
`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 First Amended Complaint as follows.
`
`The paragraph numbering in these responses corresponds to the numbered
`
`paragraphs in the First Amended Complaint.
`
`Subject to the foregoing, Qualcomm states as follows:
`
`INTRODUCTION
`
`Qualcomm is currently without knowledge or information sufficient
`
`1.
`
`to form a belief as to the truth of the allegations and characterization in Paragraph
`
`
`
`2
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0002
`
`
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`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 3 of 60 PageID #: 442
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`1 of the First Amended Complaint, and therefore denies them.
`
`2.
`
`Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 2 of the First Amended Complaint.
`
`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.
`
`6,459,625 (“the ’625 patent”); 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”); 7,572,727 (“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 First Amended 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 First Amended 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
`
`
`
`3
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0003
`
`
`
`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 4 of 60 PageID #: 443
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`corporation of Qualcomm Technologies, Inc. (“QTI”), and admits that Qualcomm
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`CDMA Technologies Asia-Pacific Pte Ltd (“QCTAP”) is a wholly-owned
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`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 denies the remaining allegations and characterizations contained
`
`in Paragraph 5 of the First Amended 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 First Amended
`
`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 First Amended Complaint.
`
`8.
`
`Qualcomm denies the allegations and characterizations contained in
`
`
`
`4
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0004
`
`
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`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 5 of 60 PageID #: 444
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`Paragraph 8 of the First Amended Complaint.
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`JURISDICTION AND VENUE
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`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 First Amended Complaint.
`
`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 First
`
`Amended 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 First Amended Complaint.
`
`12. Paragraph 12 alleges legal conclusions regarding personal jurisdiction
`
`to which no response is required. Qualcomm admits that, in a limited number of
`
`instances, QCTAP has billed U.S. entities for Qualcomm products. Qualcomm
`
`denies the remaining allegations and characterizations in Paragraph 12 of the First
`
`
`
`5
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`Patent Owner Monterey Research, LLC
`Ex. 2003, 0005
`
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`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 6 of 60 PageID #: 445
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`Amended Complaint. Specifically, Qualcomm denies that QCTAP has committed,
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`aided, abetted, contributed to and/or participated in the commission of any acts
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`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
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`Delaware residents with respect to products accused of infringing the Patents-in-
`
`Suit, 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, denies that QCTAP develops products for sale in the
`
`United States, and denies that QCTAP tests and verifies products developed in the
`
`United States before selling them 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 in this Court with respect to Qualcomm Inc. and QTI. Qualcomm
`
`denies the remaining allegations and characterizations in Paragraph 13 of the First
`
`Amended Complaint.
`
`THE PATENTS-IN-SUIT
`
`14. Qualcomm incorporates by reference its responses to the allegations
`
`contained in paragraphs 1-13 of the First Amended Complaint. To the extent an
`
`additional
`
`response
`
`is
`
`required, Qualcomm denies
`
`the allegations and
`
`characterizations contained in Paragraph 14 of the First Amended Complaint.
`
`
`
`6
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0006
`
`
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`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 7 of 60 PageID #: 446
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`A. U.S. Patent No. 6,459,625
`
`15. Qualcomm admits that U.S. Patent No. 6,459,625 (“the ‘625 patent”)
`
`is titled “Three metal process for optimizing layout density,” and was issued by the
`
`United States Patent and Trademark Office on October 1, 2002. Qualcomm
`
`acknowledges that Exhibit A to the First Amended Complaint purports to be a
`
`copy of the ‘625 patent . Qualcomm denies the remaining allegations and
`
`characterizations in Paragraph 15 of the First Amended 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 First Amended Complaint, and therefore denies them.
`
`B. U.S. Patent No. 6,534,805
`
`17. 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 B to
`
`the First Amended 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 17 of the First Amended 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 First Amended Complaint, and therefore denies them.
`
`
`
`7
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`Patent Owner Monterey Research, LLC
`Ex. 2003, 0007
`
`
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`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 8 of 60 PageID #: 447
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`C. U.S. Patent No. 6,642,573
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`19. 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
`
`Office on November 4, 2003. Qualcomm acknowledges that Exhibit C to the First
`
`Amended Complaint purports to be a copy of the ‘573 patent. Qualcomm denies
`
`the remaining allegations and characterizations in Paragraph 19 of the First
`
`Amended 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 First Amended Complaint, and therefore denies them.
`
`D. U.S. Patent No. 6,651,134
`
`21. 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 D to the First Amended Complaint purports
`
`to be a copy of the ‘134 patent. Qualcomm denies the remaining allegations and
`
`characterizations in Paragraph 21 of the First Amended 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
`
`
`
`8
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0008
`
`
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`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 9 of 60 PageID #: 448
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`Paragraph 22 of the First Amended Complaint, and therefore denies them.
`
`E. U.S. Patent No. 6,680,516
`
`23. 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 E to the First Amended Complaint purports to be a copy of the ‘516 patent
`
`and a Certificate of Correction. Qualcomm denies the remaining allegations and
`
`characterizations in Paragraph 23 of the First Amended 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 First Amended Complaint, and therefore denies them.
`
`F. U.S. Patent No. 6,765,407
`
`25. 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 F to the First Amended Complaint purports to be a copy of the ‘407
`
`patent. Qualcomm denies the remaining allegations and characterizations in
`
`Paragraph 25 of the First Amended 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
`
`
`
`9
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0009
`
`
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`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 10 of 60 PageID #: 449
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`Paragraph 26 of the First Amended Complaint, and therefore denies them.
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`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 First Amended Complaint
`
`purports to be a copy of the ‘727 patent. Qualcomm denies the remaining
`
`allegations and characterizations in Paragraph 27 of the First Amended 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 First Amended 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 First Amended
`
`Complaint purports to be a copy of the ‘797 patent. Qualcomm denies the
`
`remaining allegations and characterizations in Paragraph 29 of the First Amended
`
`Complaint.
`
`30. Qualcomm is currently without knowledge of information sufficient to
`
`
`
`10
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0010
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`
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`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 11 of 60 PageID #: 450
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`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 30 of the First Amended Complaint, and therefore denies them.
`
`FACTUAL BACKGROUND
`
`31. Qualcomm incorporates by reference its responses to the allegations
`
`contained in paragraphs 1-30 of the First Amended Complaint. To the extent an
`
`additional
`
`response
`
`is
`
`required, Qualcomm denies
`
`the allegations and
`
`characterizations contained in Paragraph 31 of the First Amended 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 (and footnote 1) of the First Amended Complaint, and therefore
`
`denies them.
`
`33. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 33 of the First Amended Complaint.
`
`34. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 34 of the First Amended Complaint.
`
`35. Qualcomm admits that material is available (as of February 19, 2020)
`
`at www.qualcomm.com. Qualcomm denies
`
`the remaining allegations and
`
`characterizations contained in Paragraph 35 of the First Amended Complaint.
`
`
`
`11
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`Patent Owner Monterey Research, LLC
`Ex. 2003, 0011
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`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 12 of 60 PageID #: 451
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` QUALCOMM’S PRE-SUIT KNOWLEDGE OF MONTEREY’S
`PATENTS AND CHARGE OF
`INFRINGEMENT
`
`36. Qualcomm admits that, before filing this , 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 lawsuit. Qualcomm denies the remaining allegations and
`
`characterizations in Paragraph 36 of the First Amended Complaint.
`
`a.
`
`Qualcomm admits that a letter bearing a date of January 31,
`
`2018 was received, to which was attached a table listing the ‘625, ’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 First Amended 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 First Amended Complaint.
`
`c.
`
`Qualcomm admits that an in-person meeting occurred on July
`
`
`
`12
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`Patent Owner Monterey Research, LLC
`Ex. 2003, 0012
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`
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`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 13 of 60 PageID #: 452
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`17, 2018. Qualcomm denies the remaining allegations and characterizations in
`
`Paragraph 36(c) of the First Amended 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 First Amended 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 First Amended 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 36(f) of the First Amended 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 First Amended 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
`
`
`
`13
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`Patent Owner Monterey Research, LLC
`Ex. 2003, 0013
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`
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`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 14 of 60 PageID #: 453
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`36(h) of the First Amended Complaint.
`
`i.
`
`Qualcomm denies
`
`the allegations and characterizations
`
`contained in Paragraph 36(i) of the First Amended Complaint.
`
`j.
`
`Qualcomm denies
`
`the allegations and characterizations
`
`contained in Paragraph 36(j) of the First Amended Complaint.
`
`37. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 37 of the First Amended Complaint.
`
`COUNT ONE
`INFRINGEMENT OF THE ’625 PATENT
`
`38. Qualcomm incorporates by reference its responses to the allegations
`
`contained in paragraphs 1-37 of the First Amended Complaint. To the extent an
`
`additional
`
`response
`
`is
`
`required, Qualcomm denies
`
`the allegations and
`
`characterizations contained in Paragraph 38 of the First Amended 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 First Amended Complaint, and therefore denies them.
`
`40. Qualcomm denies that the ‘625 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 First Amended Complaint, and therefore denies them.
`
`42. Qualcomm is currently without knowledge of information sufficient to
`
`
`
`14
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`Patent Owner Monterey Research, LLC
`Ex. 2003, 0014
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`
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`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 15 of 60 PageID #: 454
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`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 42 of the First Amended Complaint, and therefore denies them.
`
`43. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 43 of the First Amended Complaint.
`
`44. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 44 of the First Amended Complaint.
`
`45. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 45 of the First Amended Complaint.
`
`46. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 46 of the First Amended Complaint.
`
`a.
`
`Qualcomm denies
`
`the allegations and characterizations
`
`contained in Paragraph 46(a) of the First Amended Complaint.
`
`b.
`
`Qualcomm denies
`
`the allegations and characterizations
`
`contained in Paragraph 46(b) of the First Amended Complaint.
`
`c.
`
`Qualcomm denies
`
`the allegations and characterizations
`
`contained in Paragraph 46(c) of the First Amended Complaint.
`
`d.
`
`Qualcomm denies
`
`the allegations and characterizations
`
`contained in Paragraph 46(d) of the First Amended Complaint.
`
`47. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 47 of the First Amended Complaint.
`
`
`
`15
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0015
`
`
`
`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 16 of 60 PageID #: 455
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`48. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 48 of the First Amended Complaint.
`
`49. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 49 of the First Amended Complaint.
`
`50. Qualcomm admits that material is available (as of February 19, 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 50 of the First Amended Complaint.
`
`51. Qualcomm admits that material is available (as of February 19, 2020)
`
`at
`
`https://www.qualcomm.com/system/files/document/files/prod_brief_qcom_sd855_
`
`0.pdf. Qualcomm denies the remaining allegations and characterizations contained
`
`in Paragraph 51 of the First Amended Complaint.
`
`52. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 52 of the First Amended Complaint.
`
`53. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 53 of the First Amended Complaint.
`
`COUNT TWO
`INFRINGEMENT OF THE ’805 PATENT
`
`54. Qualcomm incorporates by reference its responses to the allegations
`
`contained in paragraphs 1-53 of the First Amended Complaint. To the extent an
`
`
`
`16
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0016
`
`
`
`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 17 of 60 PageID #: 456
`
`additional
`
`response
`
`is
`
`required, Qualcomm denies
`
`the allegations and
`
`characterizations contained in Paragraph 54 of the First Amended Complaint.
`
`55. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 55 of the First Amended Complaint, and therefore denies them.
`
`56. Qualcomm denies that the ‘805 patent is valid and enforceable.
`
`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 First Amended Complaint, and therefore denies them.
`
`58. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 58 of the First Amended Complaint, and therefore denies them.
`
`59. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 59 of the First Amended Complaint.
`
`60. Qualcomm admits that some of its products include SRAM with a six-
`
`transistor or eight-transistor cell design. Qualcomm denies the remaining
`
`allegations and characterizations contained in Paragraph 60 of the First Amended
`
`Complaint.
`
`61. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 61 of the First Amended Complaint.
`
`
`
`17
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0017
`
`
`
`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 18 of 60 PageID #: 457
`
`62. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 62 of the First Amended Complaint.
`
`a.
`
`Qualcomm denies
`
`the allegations and characterizations
`
`contained in Paragraph 62(a) of the First Amended Complaint.
`
`b.
`
`Qualcomm denies
`
`the allegations and characterizations
`
`contained in Paragraph 62(b) of the First Amended Complaint.
`
`63. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 63 of the First Amended Complaint.
`
`64. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 64 of the First Amended Complaint.
`
`65. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 65 of the First Amended Complaint.
`
`66. Qualcomm admits that material is available (as of February 19, 2020)
`
`at
`
`https://www.qualcomm.com/media/documents/files/snapdragon-800-product-
`
`brief.pdf. Qualcomm denies the remaining allegations and characterizations
`
`contained in Paragraph 66 of the First Amended Complaint.
`
`67. Qualcomm admits that material is available (as of February 19, 2020)
`
`at
`
`https://www.qualcomm.com/media/documents/files/snapdragon-800-product-
`
`brief.pdf. Qualcomm denies the remaining allegations and characterizations
`
`contained in Paragraph 67 of the First Amended Complaint.
`
`
`
`18
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0018
`
`
`
`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 19 of 60 PageID #: 458
`
`68. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 68 of the First Amended Complaint.
`
`69. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 69 of the First Amended Complaint.
`
`COUNT THREE
`INFRINGEMENT OF THE ’573 PATENT
`
`70. Qualcomm incorporates by reference its responses to the allegations
`
`
`
`contained in paragraphs 1-70 of the First Amended Complaint. To the extent an
`
`additional
`
`response
`
`is
`
`required, Qualcomm denies
`
`the allegations and
`
`characterizations contained in Paragraph 70 of the First Amended Complaint.
`
`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 First Amended Complaint, and therefore denies them.
`
`72. Qualcomm denies that the ‘573 patent is valid and enforceable.
`
`73. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 73 of the First Amended Complaint, and therefore denies them.
`
`74. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 74 of the First Amended Complaint, and therefore denies them.
`
`75. Qualcomm denies the allegations and characterizations contained in
`
`
`
`19
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0019
`
`
`
`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 20 of 60 PageID #: 459
`
`Paragraph 75 of the First Amended Complaint.
`
`76. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 76 of the First Amended Complaint.
`
`77. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 77 of the First Amended Complaint.
`
`a.
`
`Qualcomm denies
`
`the allegations and characterizations
`
`contained in Paragraph 77(a) of the First Amended Complaint.
`
`b.
`
`Qualcomm denies
`
`the allegations and characterizations
`
`contained in Paragraph 77(b) of the First Amended Complaint.
`
`78. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 78 of the First Amended Complaint.
`
`79. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 79 of the First Amended Complaint.
`
`80. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 80 of the First Amended Complaint.
`
`81. Qualcomm admits that material is available (as of February 19, 2020)
`
`at
`
`https://www.qualcomm.com/system/files/document/files/snapdragon_product_brie
`
`f_810_0.pdf. Qualcomm denies the remaining allegations and characterizations
`
`contained in Paragraph 81 of the First Amended Complaint.
`
`
`
`20
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0020
`
`
`
`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 21 of 60 PageID #: 460
`
`82. Qualcomm admits that material is available (as of February 19, 2020)
`
`at
`
`https://www.qualcomm.com/system/files/document/files/snapdragon_product_brie
`
`f_810_0.pdf. Qualcomm denies the remaining allegations and characterizations
`
`contained in Paragraph 82 of the First Amended Complaint.
`
`83. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 83 of the First Amended Complaint.
`
`84. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 84 of the First Amended Complaint.
`
`COUNT FOUR
`INFRINGEMENT OF THE ’134 PATENT
`
`85. Qualcomm incorporates by reference its responses to the allegations
`
`
`
`contained in paragraphs 1-84 of the First Amended Complaint. To the extent an
`
`additional
`
`response
`
`is
`
`required, Qualcomm denies
`
`the allegations and
`
`characterizations contained in Paragraph 85 of the First Amended Complaint.
`
`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 First Amended Complaint, and therefore denies them.
`
`87. Qualcomm denies that the ‘134 patent is valid and enforceable.
`
`88. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`
`
`21
`
`Patent Owner Monterey Research, LLC
`Ex. 2003, 0021
`
`
`
`Case 1:19-cv-02083-CFC Document 22 Filed 02/28/20 Page 22 of 60 PageID #: 461
`
`Paragraph 88 of the First Amended Complaint, and therefore denies them.
`
`89. Qualcomm is currently without knowledge of information sufficient to
`
`form a belief as to the truth of the allegations and characterizations contained in
`
`Paragraph 89 of the First Amended Complaint, and therefore denies them.
`
`90. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 90 of the First Amended Complaint.
`
`91. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 91 of the First Amended Complaint.
`
`92. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 92 of the First Amended Complaint.
`
`93. Qualcomm denies the allegations and characterizations contained in
`
`Paragraph 93 of the First Amended Complaint.
`
`a.
`
`Qualcomm denies
`
`the allegations and characterizations
`
`contained in Paragraph 93(a) of the First
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