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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`CYWEE GROUP LTD.,
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`Plaintiff,
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`SAMSUNG ELECTRONICS CO., LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC.
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`Defendants.
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` CASE NO. 2:17-cv-00140-RWS-RSP
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`JURY TRIAL DEMANDED
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`PLAINTIFF’S ANSWER TO DEFENDANTS’ COUNTERCLAIMS
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`Plaintiff and Counterclaim-Defendant CyWee Group Ltd. (“CyWee”) answers herein
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`Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.’s (collectively
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`“Samsung”) counterclaims (“Counterclaims”) with numbered paragraphs corresponding to like-
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`numbered paragraphs of the Counterclaims as follows. Unless expressly admitted all averments
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`asserted by Samsung in its Counterclaims are denied.
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`ANSWER TO COUNTERCLAIMS
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`300. CyWee admits the allegations in Paragraph 300.
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`301. CyWee admits the allegations in Paragraph 301.
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`302. CyWee admits that it has submitted to personal jurisdiction of this Court for
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`purposes of this litigation. CyWee denies any remaining allegations in Paragraph 302.
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`303. CyWee admits that venue is proper for the Counterclaims and further admits that
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`Samsung purports to reserve the right to move to transfer this case. CyWee denies any remaining
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`allegations in Paragraph 302.
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`Case 2:17-cv-00140-RWS-RSP Document 21 Filed 06/13/17 Page 2 of 4 PageID #: 173
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`FIRST COUNTERCLAIM
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`(Declaratory Judgment of Non-Infringement of the ’438 Patent)
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`304. Paragraph 304 restates and incorporates by reference the allegations contained in
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`Paragraphs 300-303 of the Counterclaims. In response, CyWee incorporates by reference its
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`answers to those paragraphs.
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`305. CyWee admits the allegations of Paragraph 305.
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`306. CyWee denies the allegations of Paragraph 306.
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`307. CyWee admits the allegations of Paragraph 307.
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`308. CyWee admits that Samsung seeks entry of a declaratory judgment that it does
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`not infringe any claim of the ’438 Patent, but denies that Samsung is entitled to judgment in its
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`favor.
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`SECOND COUNTERCLAIM
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`(Declaratory Judgment of Non-Infringement of the ’978 Patent)
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`309.
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` Paragraph 309 restates and incorporates by reference the allegations contained in
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`Paragraphs 300-303 of the Counterclaims. In response, CyWee incorporates by reference its
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`answers to those paragraphs.
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`310. CyWee admits the allegations of Paragraph 310.
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`311. CyWee denies the allegations of Paragraph 311.
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`312. CyWee admits the allegations of Paragraph 312.
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`313. CyWee admits that Samsung seeks entry of a declaratory judgment that it does
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`not infringe any claim of the ’978 Patent, but denies that Samsung is entitled to judgment in its
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`favor.
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`Case 2:17-cv-00140-RWS-RSP Document 21 Filed 06/13/17 Page 3 of 4 PageID #: 174
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` THIRD COUNTERCLAIM
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` (Declaratory Judgment of Invalidity of the ’438 Patent)
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`314. Paragraph 314 restates and incorporates by reference the allegations contained in
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`Paragraphs 300-303 of the Counterclaims. In response, CyWee incorporates by reference its
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`answers to those paragraphs.
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`315. CyWee denies the allegations of Paragraph 315.
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`316. CyWee admits the allegations of Paragraph 316.
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`317. CyWee admits that Samsung seeks entry of a declaratory judgment that the claims
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`of the ’438 Patent are invalid and/or enforceable but denies that Samsung is entitled to judgment
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`in its favor.
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`FOURTH COUNTERCLAIM
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`(Declaratory Judgment of Invalidity of the ’978 Patent)
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`318. Paragraph 318 restates and incorporates by reference the allegations contained in
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`Paragraphs 300-303 of the Counterclaims. In response, CyWee incorporates by reference its
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`answers to those paragraphs.
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`319. CyWee denies the allegations of Paragraph 319.
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`320.
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` CyWee admits the allegations of Paragraph 320.
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`321.
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` CyWee admits that Samsung seeks entry of a declaratory judgment that the
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`claims of the ’978 Patent are invalid and/or enforceable but denies that Samsung is entitled to
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`judgment in its favor.
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`OMNIVISION’S PRAYER FOR RELIEF
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`CyWee denies that Samsung is entitled to judgment in its favor or to any of the relief it
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`requested. CyWee further denies each and every allegation of the Counterclaims to which
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`CyWee has not specifically admitted, denied, or otherwise responded herein.
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`Case 2:17-cv-00140-RWS-RSP Document 21 Filed 06/13/17 Page 4 of 4 PageID #: 175
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` Dated: June 13, 2017
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`/s/ Ari B. Rafilson
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`
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`Michael W. Shore, Texas Bar No. 18294915
`Lead Attorney
`mshore@shorechan.com
`Alfonso Garcia Chan, Texas Bar No. 24012408
`achan@shorechan.com
`Christopher L. Evans, Texas Bar No.24058901
`cevans@shorechan.com
`Ari B. Rafilson, Texas Bar No. 24060465
`arafilson@shorechan.com
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`SHORE CHAN DePUMPO LLP
`901 Main Street, Suite 3300
`Dallas, Texas 75202
`Telephone: 214-593-9110
`Facsimile: 214-593-9111
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`ATTORNEYS FOR PLAINTIFF
`CYWEE GROUP, LTD.
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that all counsel of record who are deemed to have consented to
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`electronic service are being served with a copy of this document via the Court’s CM/ECF system
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`per Local Rule CV-5(a)(3) on June 13, 2017.
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`/s/ Ari B. Rafilson
`Ari B. Rafilson
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