Case 2:23-cv-00212-JRG Document 102 Filed 01/19/24 Page 1 of 24 PageID #: 3398
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`GREENTHREAD, LLC,
`
`Plaintiff,
`
`v.
`
`OMNIVISION TECHNOLOGIES, INC.,
`
`Defendant.
`
`GREENTHREAD, LLC,
`
`Plaintiff,
`
`v.
`
`TEXAS INSTRUMENTS INCORPORATED,
`
`Defendant.
`
`GREENTHREAD, LLC,
`
`Plaintiff,
`
`v.
`
`AMS-OSRAM AG ET AL.
`
`Defendant.
`
`Case No. 2:23-cv-00212-JRG
`(Consolidated Lead Case)
`
`JURY TRIAL DEMANDED
`
`Case No. 2:23-cv-00157-JRG
`(Member Case)
`
`JURY TRIAL DEMANDED
`
`Case No. 2:23-cv-00179-JRG
`(Member Case)
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF’S ANSWER AND AFFIRMATIVE DEFENSES TO DEFENDANT
`OMNIVISION TECHNOLOGIES, INC.’S COUNTERCLAIMS
`
`Plaintiff Greenthread, LLC (“Greenthread”) hereby submits its Answer and Affirmative
`
`Defenses to OmniVision Technologies, Inc.’s (“OmniVision”) Counterclaims and respectfully
`
`shows the Court as follows:
`
`IPR2024-001, -00016, -00017, -00018, -00019,
`-00020, -00021 Ex. 3002
`
`

`

`Case 2:23-cv-00212-JRG Document 102 Filed 01/19/24 Page 2 of 24 PageID #: 3399
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`THE PARTIES
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`1.
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`Plaintiff admits that OmniVision is a corporation organized and existing under the
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`laws of Delaware. Plaintiff lacks sufficient information to form a belief as to the truth or falsity of
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`the remaining allegations set out in Paragraph 1 of the counterclaims and therefore denies the same.
`
`2.
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`3.
`
`Plaintiff admits the allegations of Paragraph 2 in the counterclaims.
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`JURISDICTION AND VENUE
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`Paragraph 3 is a legal conclusion to which no response is required. To the extent a
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`response is required, Plaintiff admits that this Court has subject matter jurisdiction over actions for
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`declaratory judgment actions under 28 U.S.C. §§ 1331, 1338(a), 2201, and 2202. Plaintiff denies
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`the remaining allegations in Paragraph 3.
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`4.
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`Plaintiff admits that personal jurisdiction is proper in this judicial district for
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`purposes of Defendant’s counterclaims. Plaintiff otherwise denies the remaining allegations of
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`Paragraph 4.
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`BACKGROUND
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`5.
`
`Paragraph 5 is OmniVision’s characterization of Greenthread’s Complaint and
`
`corresponding exhibits. See Dkt. 1. Greenthread refers to those documents for a complete and
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`accurate description of what they say. To the extent paragraph 5 is inconsistent with the
`
`Complaint, Greenthread denies the allegations of paragraph 5.
`
`6.
`
`Paragraph 6 is OmniVision’s characterization of Greenthread’s Complaint and
`
`corresponding exhibits. See Dkt. 1. Greenthread refers to those documents for a complete and
`
`accurate description of what they say. To the extent paragraph 6 is inconsistent with the
`
`Complaint, Greenthread denies the allegations of paragraph 6.
`
`7.
`
`8.
`
`Plaintiff admits the allegations of Paragraph 7 of the counterclaims.
`
`Paragraph 8 is OmniVision’s characterization of Greenthread’s licensing
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`2
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`

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`Case 2:23-cv-00212-JRG Document 102 Filed 01/19/24 Page 3 of 24 PageID #: 3400
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`
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`agreements which are described in GT-EDTX-OV_0000001-000058, GT-EDTX_0001643-
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`0001678, and GT-EDTX_0011564-0011606. Greenthread refers to those documents for a
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`complete and accurate description of what they say. To the extent paragraph 8 is inconsistent with
`
`Greenthread’s licensing agreements, Greenthread denies the allegations of paragraph 8.
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`9.
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`10.
`
`11.
`
`12.
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`Plaintiff denies the allegations of Paragraph 9 in the counterclaims.
`
`Plaintiff admits the allegations of Paragraph 10 in the counterclaims.
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`Plaintiff admits the allegations of Paragraph 11 in the counterclaims.
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`Paragraph 12 is OmniVision’s characterization of Greenthread’s Response in
`
`Opposition to the Motion to Compel Compliance with P.R. 3-1 and Strike Uncharted Products,
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`Greenthread refers to those documents for a complete and accurate description of what they say.
`
`To the extent paragraph 12 is inconsistent with Greenthread’s Response in Opposition to the
`
`Motion to Compel Compliance with P.R. 3-1 and Strike Uncharted Products, Greenthread denies
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`the allegations of paragraph 12.
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`13.
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`Greenthread admits
`
`it
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`they obtained a Tech
`
`Insights
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`report
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`for
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`the
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`OmniVision24A1Q image sensor. Greenthread lacks sufficient information to form a belief as to
`
`the truth or falsity of the remaining allegations set out in Paragraph 13 of the counterclaims and
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`therefore denies the same.
`
`14.
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`Paragraph 14 is OmniVision’s characterization of Greenthread’s Complaint and
`
`corresponding exhibits. Greenthread refers to those documents for a complete and accurate
`
`description of what they say. To the extent paragraph 14 is inconsistent with the Complaint,
`
`Greenthread denies the allegations of paragraph 14.
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`15.
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`Paragraph 15 is OmniVision’s characterization of Greenthread’s Complaint and
`
`corresponding exhibits. Greenthread refers to those documents for a complete and accurate
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`3
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`
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`description of what they say. To the extent paragraph 15 is inconsistent with the Complaint,
`
`Greenthread denies the allegations of paragraph 15.
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`16.
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`Paragraph 16 is OmniVision’s characterization of Greenthread’s Complaint and
`
`corresponding exhibits. Greenthread refers to those documents for a complete and accurate
`
`description of what they say. To the extent paragraph 16 is inconsistent with the Complaint,
`
`Greenthread denies the allegations of paragraph 16.
`
`17.
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`Paragraph 17 is OmniVision’s characterization of Greenthread’s Response in
`
`Opposition to the Motion to Dismiss Complaint. Greenthread refers to this document for a
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`complete and accurate description of what it says. To the extent paragraph 17 is inconsistent with
`
`Greenthread’s Response in Opposition to the Motion to Dismiss Complaint, Greenthread denies
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`the allegations of paragraph 17.
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`18.
`
`Plaintiff lacks sufficient information to form a belief as to the truth or falsity of the
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`remaining allegations set out in Paragraph 18 of the counterclaims and therefore denies the same.
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`19.
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`Plaintiff lacks sufficient information to form a belief as to the truth or falsity of the
`
`remaining allegations set out in Paragraph 19 of the counterclaims and therefore denies the same.
`
`20.
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`Paragraph 20 is OmniVision’s characterization of Greenthread’s Complaint and
`
`corresponding exhibits. Greenthread refers to those documents for a complete and accurate
`
`description of what they say. To the extent paragraph 20 is inconsistent with the Complaint,
`
`Greenthread denies the allegations of paragraph 20.
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`21.
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`Paragraph 21 is OmniVision’s characterization of Greenthread’s Complaint and
`
`corresponding exhibits. Greenthread refers to those documents for a complete and accurate
`
`description of what they say. To the extent paragraph 21 is inconsistent with the Complaint,
`
`Greenthread denies the allegations of paragraph 21.
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`4
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`
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`22.
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`Paragraph 22 is OmniVision’s characterization of Greenthread’s Complaint and
`
`corresponding exhibits. Greenthread refers to those documents for a complete and accurate
`
`description of what they say. To the extent paragraph 22 is inconsistent with the Complaint,
`
`Greenthread denies the allegations of paragraph 22.
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`23.
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`Paragraph 23 is OmniVision’s characterization of Greenthread’s Infringement
`
`Contentions. Greenthread refers to those documents for a complete and accurate description of
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`what they say. To the extent paragraph 23 is inconsistent with Greenthread’s Infringement
`
`Contentions, Greenthread denies the allegations of paragraph 23.
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`24.
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`Paragraph 24 is OmniVision’s characterization of Greenthread’s Infringement
`
`Contentions. Greenthread refers to those documents for a complete and accurate description of
`
`what they say. To the extent paragraph 24 is inconsistent with Greenthread’s Infringement
`
`Contentions, Greenthread denies the allegations of paragraph 24.
`
`25.
`
`26.
`
`Plaintiff denies the allegations of Paragraph 25 of the counterclaims.
`
`Paragraph 26 is OmniVision’s characterization of Greenthread’s Infringement
`
`Contentions. Greenthread refers to those documents for a complete and accurate description of
`
`what they say. To the extent paragraph 23 is inconsistent with Greenthread’s Infringement
`
`Contentions, Greenthread denies the allegations of paragraph 23.
`
`27.
`
`Plaintiff lacks sufficient information to form a belief as to the truth or falsity of the
`
`remaining allegations set out in Paragraph 27 of the counterclaims and therefore denies the same.
`
`28.
`
`Paragraph 28 is OmniVision’s characterization of OmniVisionTI0043333-
`
`OmniVisionTI0043423. Greenthread refers to those documents for a complete and accurate
`
`description of what they say. To the extent paragraph 28 is inconsistent with the OmnivVision3610
`
`Report, Greenthread denies the allegations of paragraph 28.Greenthread lacks information
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`5
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`
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`sufficient to form a belief as to OmniVision’s claims regarding OmniVision3610 and therefore
`
`denies them.
`
`29.
`
`Paragraph 29 is OmniVision’s characterization of OmniVisionTI0043333-
`
`OmniVisionTI0043423. Greenthread refers to those documents for a complete and accurate
`
`description of what they say. To the extent paragraph 29 is inconsistent with the OmnivVision3610
`
`Report, Greenthread denies the allegations of paragraph 29. Greenthread lacks information
`
`sufficient to form a belief as to OmniVision’s claims regarding OmniVision3610 and therefore
`
`denies them.
`
`30.
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`Paragraph 30 is OmniVision’s characterization of OmniVisionTI0043333-
`
`OmniVisionTI0043423. Greenthread refers to those documents for a complete and accurate
`
`description of what they say. To the extent paragraph 30 is inconsistent with the OmnivVision3610
`
`Report, Greenthread denies the allegations of paragraph 30. Greenthread lacks information
`
`sufficient to form a belief as to OmniVision’s claims regarding OmniVision3610 and therefore
`
`denies them.
`
`31.
`
`Paragraph 31 is OmniVision’s characterization of OmniVisionTI0043333-
`
`OmniVisionTI0043423. Greenthread refers to those documents for a complete and accurate
`
`description of what they say. To the extent paragraph 31 is inconsistent with the OmnivVision3610
`
`Report, Greenthread denies the allegations of paragraph 31. Greenthread lacks information
`
`sufficient to form a belief as to OmniVision’s claims regarding OmniVision3610 and therefore
`
`denies them.
`
`32.
`
`Paragraph 32 is OmniVision’s characterization of OmniVisionTI0043333-
`
`OmniVisionTI0043423. Greenthread refers to those documents for a complete and accurate
`
`description of what they say. To the extent paragraph 32 is inconsistent with the OmnivVision3610
`
`6
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`
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`Report, Greenthread denies the allegations of paragraph 32. Greenthread lacks information
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`sufficient to form a belief as to OmniVision’s claims regarding OmniVision3610 and therefore
`
`denies them.
`
`33.
`
`Paragraph 33
`
`is OmniVision’s characterization of
`
`the Asserted Patents,
`
`Greenthread refers to those documents for a complete and accurate description of what they say.
`
`To the extent paragraph 33 is inconsistent with the Asserted Patents, Greenthread denies the
`
`allegations of paragraph 33.
`
`34.
`
`Plaintiff admits that certain transistors existed prior to 2003. Greenthread denies
`
`that Dr. Rao did not invent the transistors described in the Greenthread patents. To the extent that
`
`Paragraph 34 constitutes an assertion regarding the scope and content of the prior art, it is a legal
`
`conclusion to which no response is required. Plaintiff otherwise denies the remaining allegations
`
`of Paragraph 34 in the counterclaims.
`
`35.
`
`Greenthread denies that Dr. Rao did not invent the active regions described in the
`
`Greenthread patents. To the extent that Paragraph 35 constitutes an assertion regarding the scope
`
`and content of the prior art, it is a legal conclusion to which no response is required. Plaintiff
`
`otherwise denies the remaining allegations of Paragraph 35 in the counterclaims.
`
`36.
`
`The allegations of Paragraph 36 in the counterclaims are an incomplete hypothetical
`
`and call for expert testimony. Given the incomplete nature of Omnivision’s allegations,
`
`Greenthread lacks sufficient information to form a belief as to the truth or falsity of the allegations
`
`set out in Paragraph 36 of the counterclaims and therefore denies the same.
`
`37.
`
`The allegations of Paragraph 37 in the counterclaims are an incomplete hypothetical
`
`and call for expert testimony. Given the incomplete nature of Omnivision’s allegations,
`
`Greenthread lacks sufficient information to form a belief as to the truth or falsity of the allegations
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`7
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`Case 2:23-cv-00212-JRG Document 102 Filed 01/19/24 Page 8 of 24 PageID #: 3405
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`
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`set out in Paragraph 37 of the counterclaims and therefore denies the same
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`38.
`
`Paragraph 38
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`is OmniVision’s characterization of
`
`the Asserted Patents,
`
`Greenthread refers to those documents for a complete and accurate description of what they say.
`
`To the extent paragraph 38 is inconsistent with the Asserted Patents, Greenthread denies the
`
`allegations of paragraph 38.
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`39.
`
`The allegations of Paragraph 39 in the counterclaims are an incomplete hypothetical
`
`and call for expert testimony. Given the incomplete nature of Omnivision’s allegations,
`
`Greenthread lacks sufficient information to form a belief as to the truth or falsity of the allegations
`
`set out in Paragraph 39 of the counterclaims and therefore denies the same.
`
`40.
`
`The allegations of Paragraph 40 in the counterclaims are an incomplete hypothetical
`
`and call for expert testimony. Given the incomplete nature of Omnivision’s allegations,
`
`Greenthread lacks sufficient information to form a belief as to the truth or falsity of the allegations
`
`set out in Paragraph 40 of the counterclaims and therefore denies the same.
`
`41.
`
`Paragraph 41 is OmniVision’s characterization of the prosecution history of the
`
`Asserted Patents, Greenthread refers to those documents for a complete and accurate description
`
`of what they say. To the extent paragraph 41 is inconsistent with the prosecution history,
`
`Greenthread denies the allegations of paragraph 41.
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`42.
`
`Paragraph 42 is OmniVision’s characterization of the prosecution history of the
`
`Asserted Patents, Greenthread refers to those documents for a complete and accurate description
`
`of what they say. To the extent paragraph 42 is inconsistent with the prosecution history,
`
`Greenthread denies the allegations of paragraph 42.
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`43.
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`Paragraph 43 is OmniVision’s characterization of the prosecution history of the
`
`Asserted Patents, Greenthread refers to those documents for a complete and accurate description
`
`8
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`
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`of what they say. To the extent paragraph 43 is inconsistent with the prosecution history,
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`Greenthread denies the allegations of paragraph 43.
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`44.
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`Paragraph 44 is OmniVision’s characterization of the prosecution history of the
`
`Asserted Patents, Greenthread refers to those documents for a complete and accurate description
`
`of what they say. To the extent paragraph 44 is inconsistent with the prosecution history,
`
`Greenthread denies the allegations of paragraph 44.
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`45.
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`Paragraph 45 is OmniVision’s characterization of case no. 2:19-cv-00147-JRG.
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`Greenthread refers to the documents in that case for a complete and accurate description of what
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`they say. To the extent paragraph 45 is inconsistent those documents, Greenthread denies the
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`allegations of paragraph 45.
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`46.
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`Paragraph 46
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`is OmniVision’s characterization of
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`the Asserted Patents.
`
`Greenthread refers to those documents for a complete and accurate description of what they say.
`
`To the extent paragraph 46 is inconsistent with the Asserted Patents, Greenthread denies the
`
`allegations of paragraph 46.
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`47.
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`Paragraph 47 is OmniVision’s characterization of Greenthread’s Responsive Claim
`
`Construction Brief in Case No. 6:22-cv-00105-ADA. Greenthread refers to those documents for a
`
`complete and accurate description of what they say. To the extent paragraph 47 is inconsistent
`
`with Greenthread’s Responsive Claim Construction Brief in Case No. 6:22-cv-00105-ADA,
`
`Greenthread denies the allegations of paragraph 47.
`
`48.
`
`Paragraph 48 is OmniVision’s characterization of the Claim Construction
`
`Memorandum and Order in Case No. . 2:19-cv-00147-JRG (E.D. Tex), Greenthread refers to those
`
`documents for a complete and accurate description of what they say. To the extent paragraph 48
`
`is inconsistent with the Claim Construction Memorandum and Order in Case No. 2:19-cv-00147-
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`9
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`
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`JRG (E.D. Tex), Greenthread denies the allegations of paragraph 48.
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`49.
`
`50.
`
`Plaintiff denies the allegations of Paragraph 49 in the counterclaims.
`
`Paragraph 50 is OmniVision’s characterization of the prosecution history of the
`
`’195 Patent, Greenthread refers to those documents for a complete and accurate description of
`
`what they say. To the extent paragraph 50 is inconsistent with prosecution history of the ’195
`
`Patent, Greenthread denies the allegations of paragraph 50.
`
`51.
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`Paragraph 51 is OmniVision’s characterization of claim construction briefing in
`
`Case No. 6:22-cv-00105-ADA, Greenthread refers to those documents for a complete and accurate
`
`description of what they say. To the extent paragraph 51 is inconsistent with the claim construction
`
`in Case No. 6:22-cv-00105-ADA, Greenthread denies the allegations of paragraph 51.
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`52.
`
`Paragraph 52 is OmniVision’s characterization of Greenthread’s Responsive Claim
`
`Construction Brief in Case No. 1:23-cv-00369-DC. Greenthread refers to those documents for a
`
`complete and accurate description of what they say. To the extent paragraph 52 is inconsistent
`
`with Greenthread’s Responsive Claim Construction Brief in Case No. 1:23-cv-00369-DC,
`
`Greenthread denies the allegations of paragraph 52.
`
`53.
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`Paragraph 53 is OmniVision’s characterization of the prosecution history of the
`
`’842 Patent, Greenthread refers to those documents for a complete and accurate description of
`
`what they say. To the extent paragraph 53 is inconsistent with prosecution history of the ’842
`
`Patent, Greenthread denies the allegations of paragraph 53.
`
`54.
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`Paragraph 54 is OmniVision’s characterization of U.S. Patent Publication No.
`
`2007/0045682, Greenthread refers to that document for a complete and accurate description of
`
`what it says. To the extent paragraph 54 is inconsistent with U.S. Patent Publication No.
`
`2007/0045682, Greenthread denies the allegations of paragraph 54.
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`10
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`
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`55.
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`Paragraph 55 is OmniVision’s characterization of U.S. Patent Publication No.
`
`2007/0045682, Greenthread refers to that document for a complete and accurate description of
`
`what it says. To the extent paragraph 55 is inconsistent with U.S. Patent Publication No.
`
`2007/0045682, Greenthread denies the allegations of paragraph 55.
`
`56.
`
`Paragraph 56 is OmniVision’s characterization of the prosecution history of the
`
`’842 Patent, Greenthread refers to those documents for a complete and accurate description of
`
`what they say. To the extent paragraph 56 is inconsistent with prosecution history of the ’842
`
`Patent, Greenthread denies the allegations of paragraph 56.
`
`57.
`
`Paragraph 57 is OmniVision’s characterization of the prosecution history of the
`
`’842 Patent, Greenthread refers to those documents for a complete and accurate description of
`
`what they say. To the extent paragraph 57 is inconsistent with prosecution history of the ’842
`
`Patent, Greenthread denies the allegations of paragraph 57.
`
`58.
`
`Paragraph 58 is OmniVision’s characterization of the prosecution history of the
`
`’842 Patent, Greenthread refers to those documents for a complete and accurate description of
`
`what they say. To the extent paragraph 58 is inconsistent with prosecution history of the ’842
`
`Patent, Greenthread denies the allegations of paragraph 58.
`
`59.
`
`Paragraph 59 is OmniVision’s characterization of the prosecution history of the
`
`’842 Patent, Greenthread refers to those documents for a complete and accurate description of
`
`what they say. To the extent paragraph 59 is inconsistent with prosecution history of the ’842
`
`Patent, Greenthread denies the allegations of paragraph 59.
`
`60.
`
`Paragraph 60 is OmniVision’s characterization of the prosecution history of the
`
`’842 Patent, Greenthread refers to those documents for a complete and accurate description of
`
`what they say. To the extent paragraph 60 is inconsistent with prosecution history of the ’842
`
`11
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`
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`Patent, Greenthread denies the allegations of paragraph 60.
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`61.
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`Paragraph 61 is a legal conclusion to which no response is required. To the extent
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`that a response is required, Plaintiff admits that Defendant infringes Plaintiff’s patents, admits that
`
`the Plaintiff’s patents are valid and denies the remaining allegations of Paragraph 61of the
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`counterclaims.
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`62.
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`Greenthread admits that OmniVision has said certain of its products are
`
`manufactured by TSMC and that Omnivision claims those products are accused. Greenthread
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`otherwise denies the allegations in paragraph 62.
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`COUNTERCLAIM COUNT ONE
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`(Declaratory Judgment of Patent Invalidity of the ‘195 Patent)
`
`Plaintiff incorporates by reference all of the foregoing paragraphs.
`
`Plaintiff denies the allegations of Paragraph 64 of the counterclaims.
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`Plaintiff denies the allegations of Paragraph 65 of the counterclaims.
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`COUNTERCLAIM COUNT TWO
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`(Declaratory Judgment of Patent Invalidity of the ‘502 Patent)
`
`Plaintiff incorporates by reference all of the foregoing paragraphs.
`
`Plaintiff denies the allegations of Paragraph 67of the counterclaims.
`
`Plaintiff denies the allegations of Paragraph 68 of the counterclaims.
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`COUNTERCLAIM COUNT THREE
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`(Declaratory Judgment of Patent Invalidity of the ‘842 Patent)
`
`Plaintiff incorporates by reference all of the foregoing paragraphs.
`
`Plaintiff denies the allegations of Paragraph 70 of the counterclaims.
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`Plaintiff denies the allegations of Paragraph 71 of the counterclaims.
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`63.
`
`64.
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`65.
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`66.
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`67.
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`68.
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`69.
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`70.
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`71.
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`12
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`Case 2:23-cv-00212-JRG Document 102 Filed 01/19/24 Page 13 of 24 PageID #: 3410
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`COUNTERCLAIM COUNT FOUR
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`(Declaratory Judgment of Patent Invalidity of the ‘481 Patent)
`
`Plaintiff incorporates by reference all of the foregoing paragraphs.
`
`Plaintiff denies the allegations of Paragraph 73 of the counterclaims.
`
`Plaintiff denies the allegations of Paragraph 74 of the counterclaims.
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`COUNTERCLAIM COUNT FIVE
`
`(Declaratory Judgment of Patent Invalidity of the ‘222 Patent)
`
`Plaintiff incorporates by reference all of the foregoing paragraphs.
`
`Plaintiff denies the allegations of Paragraph 76 of the counterclaims.
`
`Plaintiff denies the allegations of Paragraph 77 of the counterclaims.
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`COUNTERCLAIM COUNT SIX
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`(Declaratory Judgment of Patent Invalidity of the ‘014 Patent)
`
`Plaintiff incorporates by reference all of the foregoing paragraphs.
`
`Plaintiff denies the allegations of Paragraph 79 of the counterclaims.
`
`Plaintiff denies the allegations of Paragraph 80 of the counterclaims.
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`COUNTERCLAIM COUNT SEVEN
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`(Declaratory Judgment of Non-Infringement of the ‘195 Patent)
`
`Plaintiff incorporates by reference all of the foregoing paragraphs.
`
`Plaintiff denies the allegations in Paragraph 82 of the counterclaims.
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`Plaintiff objects that the allegation of Paragraph 83 is vague, ambiguous, and
`
`72.
`
`73.
`
`74.
`
`75.
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`76.
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`77.
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`78.
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`79.
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`80.
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`81.
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`82.
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`83.
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`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
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`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`OmniVision.
`
`84.
`
`Plaintiff objects that the allegation of Paragraph 84 is vague, ambiguous, and
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`13
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`Case 2:23-cv-00212-JRG Document 102 Filed 01/19/24 Page 14 of 24 PageID #: 3411
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`
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`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
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`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`OmniVision.
`
`85.
`
`Plaintiff objects that the allegation of Paragraph 85 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`OmniVision.
`
`86.
`
`Plaintiff objects that the allegation of Paragraph 86 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`OmniVision.
`
`87.
`
`Plaintiff objects that the allegation of Paragraph 87 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff denies that
`
`the Court has subject matter jurisdiction over Counterclaim Count Seven. Plaintiff denies that
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`OmniVision is entitled to any relief whatsoever.
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`COUNTERCLAIM COUNT EIGHT
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`(Declaratory Judgment of Non-Infringement of the ‘502 Patent)
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`Plaintiff incorporates by reference all of the foregoing paragraphs.
`
`Plaintiff objects that the allegation of Paragraph 89 is vague, ambiguous, and
`
`88.
`
`89.
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`OmniVision.
`
`90.
`
`Plaintiff objects that the allegation of Paragraph 90 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`14
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`Case 2:23-cv-00212-JRG Document 102 Filed 01/19/24 Page 15 of 24 PageID #: 3412
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`
`
`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`OmniVision.
`
`91.
`
`Plaintiff objects that the allegation of Paragraph 91 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`OmniVision.
`
`92.
`
`Plaintiff objects that the allegation of Paragraph 92 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`OmniVision.
`
`93.
`
`Plaintiff objects that the allegation of Paragraph 93 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`OmniVision.
`
`94.
`
`Plaintiff objects that the allegation of Paragraph 94 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVisions’s allegation is comprehensible, Plaintiff denies that
`
`the Court has subject matter jurisdiction over Counterclaim Count eight. Plaintiff denies that
`
`Omnivison is entitled to any relief whatsoever.
`
`COUNTERCLAIM COUNT NINE
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`(Declaratory Judgment of Non-Infringement of the ‘842 Patent)
`
`Plaintiff incorporates by reference all of the foregoing paragraphs.
`
`Plaintiff objects that the allegation of Paragraph 96 is vague, ambiguous, and
`
`95.
`
`96.
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`15
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`Case 2:23-cv-00212-JRG Document 102 Filed 01/19/24 Page 16 of 24 PageID #: 3413
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`OmniVision.
`
`
`
`97.
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`Plaintiff objects that the allegation of Paragraph 97 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`information sufficient to form a belief as to the nature of any products TSMC may provide to
`
`OmniVision.
`
`98.
`
`Plaintiff objects that the allegation of Paragraph 98 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`OmniVision.
`
`99.
`
`Plaintiff objects that the allegation of Paragraph 99 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`OmniVision.
`
`100. Plaintiff objects that the allegation of Paragraph 100 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`OmniVision.
`
`101. Plaintiff objects that the allegation of Paragraph 101 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVisions’s allegation is comprehensible, Plaintiff denies that
`
`the Court has subject matter jurisdiction over Counterclaim Count nine. Plaintiff denies that
`
`Omnivison is entitled to any relief whatsoever.
`
`COUNTERCLAIM COUNT TEN
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`(Declaratory Judgment of Non-Infringement of the ‘481 Patent)
`
`102. Plaintiff incorporates by reference all of the foregoing paragraphs.
`
`16
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`Case 2:23-cv-00212-JRG Document 102 Filed 01/19/24 Page 17 of 24 PageID #: 3414
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`
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`103. Plaintiff objects that the allegation of Paragraph 103 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`OmniVision.
`
`104. Plaintiff objects that the allegation of Paragraph 104 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`OmniVision.
`
`105. Plaintiff objects that the allegation of Paragraph 105 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`OmniVision.
`
`106. Plaintiff objects that the allegation of Paragraph 106 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`OmniVision.
`
`107. Plaintiff objects that the allegation of Paragraph 107 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`OmniVision.
`
`108. Plaintiff objects that the allegation of Paragraph 108 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVisions’s allegation is comprehensible, Plaintiff denies that
`
`the Court has subject matter jurisdiction over Counterclaim Count nine. Plaintiff denies that
`
`17
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`Case 2:23-cv-00212-JRG Document 102 Filed 01/19/24 Page 18 of 24 PageID #: 3415
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`Omnivison is entitled to any relief whatsoever.
`
`
`
`COUNTERCLAIM COUNT ELEVEN
`
`(Declaratory Judgment of Non-Infringement of the ‘222 Patent)
`
`109. Plaintiff incorporates by reference all of the foregoing paragraphs.
`
`110. Plaintiff objects that the allegation of Paragraph 110 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`information sufficient to form a belief as to the nature of products TSMC may provide to
`
`OmniVision.
`
`111. Plaintiff objects that the allegation of Paragraph 111 is vague, ambiguous, and
`
`incomprehensible. To the extent OmniVision’s allegation is comprehensible, Plaintiff lacks
`
`information sufficient to form a belief as to the nature o