`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`STORMSEAL USA, LLC and SYSTEM
`STORMSEAL PTY LTD.,
`
`
` Plaintiffs,
`
`
` v.
`
`SRS DISTRIBUTION INC.,
`
`Defendant.
`
`
`
`
`CIVIL ACTION NO. 2:23-cv-391
`
`JURY TRIAL DEMANDED
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`
`
`DEFENDANT SRS DISTRIBUTION INC.’S ANSWER, AFFIRMATIVE DEFENSES,
`AND COUNTERCLAIMS TO PLAINTIFFS STORMSEAL USA, LLC AND SYSTEM
`STORMSEAL PTY LTD.’S COMPLAINT FOR PATENT INFRINGEMENT
`
`Defendant SRS Distribution Inc. (“Defendant” or “SRS”) files its Answer, Affirmative
`
`Defenses, and Counterclaims to Plaintiffs Stormseal USA, LLC and Stormseal Pty Ltd.’s
`
`(collectively, “Plaintiffs” or “Stormseal”) Complaint filed on August 29, 2023 (Dkt. No. 1)
`
`(“Complaint”). SRS denies that it is liable for infringement of any valid claim of U.S. Patent No.
`
`11,168,484 (“the ’484 Patent”).
`
`Each numbered paragraph below corresponds to the same-numbered paragraph (each a
`
`“Paragraph”) in Stormseal’s Complaint. SRS denies all allegations, whether express or implied,
`
`that are not specifically admitted below. Any factual allegation below is admitted only as to the
`
`specific admitted facts, not as to any purported conclusions, characterizations, implications, or
`
`speculations that arguably follow from the admitted facts. SRS denies that Stormseal is entitled to
`
`the relief requested or any other relief. SRS responds to Stromseal’s Complaint as follows:
`
`
`
`Exhibit 2007, Page 1 of 14
`IPR2024-00084
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`
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`Exhibit 2007, Page 2 of 14
`IPR2024-00084
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`
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`Exhibit 2007, Page 3 of 14
`IPR2024-00084
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`
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`Exhibit 2007, Page 4 of 14
`IPR2024-00084
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`
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`Exhibit 2007, Page 5 of 14
`IPR2024-00084
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`
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`Exhibit 2007, Page 6 of 14
`IPR2024-00084
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`
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`Exhibit 2007, Page 7 of 14
`IPR2024-00084
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`
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`Exhibit 2007, Page 8 of 14
`IPR2024-00084
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`Exhibit 2007, Page 9 of 14
`IPR2024-00084
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`Exhibit 2007, Page 10 of 14
`IPR2024-00084
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`Exhibit 2007, Page 11 of 14
`IPR2024-00084
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`Exhibit 2007, Page 12 of 14
`IPR2024-00084
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`
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`Exhibit 2007, Page 13 of 14
`IPR2024-00084
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`
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`Exhibit 2007, Page 14 of 14
`IPR2024-00084
`
`

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