Case 2:21-cv-00446-JRG Document 19 Filed 04/05/22 Page 1 of 32 PageID #: 207
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`
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`The CALIFORNIA INSTITUTE OF
`TECHNOLOGY,
`
`
`
`
`Plaintiff,
`
`v.
`
`
`SAMSUNG ELECTRONICS CO., LTD. and
`SAMSUNG ELECTRONICS AMERICA,
`INC.
`
`
`Defendants.
`
`
`Case No. 2:21-CV-0446-JRG
`
`JURY TRIAL DEMANDED
`
`DEFENDANTS SAMSUNG ELECTRONICS CO., LTD.’S AND SAMSUNG
`ELECTRONICS AMERICA, INC.’S ANSWER
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`
`
`

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`Case 2:21-cv-00446-JRG Document 19 Filed 04/05/22 Page 2 of 32 PageID #: 208
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`Defendants Samsung Electronics Co., Ltd. (“SEC”) and Samsung Electronics America,
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`Inc. (“SEA”) (collectively, “Samsung”) hereby submit their Answer to Plaintiff The California
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`Institute of Technology’s (“Caltech” or “Plaintiff”) Complaint. Samsung denies all allegations in
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`Caltech’s Complaint unless expressly admitted in the following paragraphs. Any admissions
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`herein are for purposes of this matter only. Samsung also reserves the right to take further positions
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`and raise additional defenses and counterclaims that may become apparent as a result of additional
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`information discovered subsequent to filing the Answer.
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`COMPLAINT FOR PATENT INFRINGEMENT*
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`1.
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`Samsung admits that Plaintiff purports to set forth an action for patent infringement
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`of U.S. Patent No. 7,116,710 (the “’710 patent”), U.S. Patent No. 7,421,032 (the “’032 patent”),
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`U.S. Patent No. 7,716,552 (the “’552 patent”), U.S. Patent No. 7,916,781 (the “’781 patent”), and
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`U.S. Patent No. 8,284,833 (the “’833 patent”) (collectively, “the Asserted Patents”) against
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`Samsung arising under the patent laws of the United States, 35 U.S.C. §§ 1 et seq. Samsung denies
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`committing any acts of infringement at any time. Samsung denies any remaining allegations in
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`Paragraph 1 of the Complaint.
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`2.
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`Samsung admits that certain public documents reflect a jury found Apple and
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`Broadcom infringed certain claims of the ’710, ’032, and ’781 patents and awarded Caltech more
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`than $1 billion in damages, but the litigation documents are heavily redacted and the Federal
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`Circuit vacated the judgment of infringement for the ’781 patent and the damages award in its
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`entirety and then remanded for a new trial. California Inst. of Tech. v. Broadcom Ltd., 25 F.4th
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`976, 980 (Fed. Cir. 2022). Samsung denies committing any acts of infringement at any time.
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`* Samsung restates the heading used in Plaintiff’s Complaint, but the use of Plaintiff’s headings
`should not be construed as an admission by Samsung. For example, as set forth below, Samsung
`denies any alleged patent infringement.
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`1
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`Samsung admits that Caltech seeks a reasonable royalty from Samsung, but Samsung denies that
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`any is owed. Samsung denies any remaining allegations in Paragraph 2 of the Complaint.
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`THE PARTIES
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`3.
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`Samsung lacks knowledge or information sufficient to form a belief as to the truth
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`of the allegations in Paragraph 3 of the Complaint and, on that basis, denies them.
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`4.
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`Samsung lacks knowledge or information sufficient to form a belief as to the truth
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`of the allegations in Paragraph 4 of the Complaint and, on that basis, denies them.
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`5.
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`Samsung admits that SEC is a corporation organized and existing under the laws of
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`the Republic of Korea with a principal place of business at 129 Samsung-ro, Maetan-3dong,
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`Yeongtong-gu Suwon-si, Gyeonggi-do, 16677, Korea. Samsung denies the remaining allegations
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`in Paragraph 5 of the Complaint.
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`6.
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`Samsung admits that SEA is a wholly owned subsidiary of SEC. Samsung admits
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`that SEA is incorporated under the laws of New York with a principal place of business at 85
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`Challenger Road, Ridgefield Park, New Jersey 07660. Samsung admits that SEA has offices at
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`6625 Excellence Way, Plano, Texas 75023. Samsung further admits that SEA may be served with
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`process through its registered agent with the Texas Secretary of State, CT Corporation System,
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`1999 Bryan Street, Suite 900, Dallas, Texas 75201. Samsung denies the remaining allegations in
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`Paragraph 6 of the Complaint.
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`7.
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`Samsung admits that SEA is involved in sales and distribution of certain Samsung
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`consumer electronics products in the United States. Samsung denies that it has committed any
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`acts of infringement as alleged by Caltech and denies the remaining allegations in Paragraph 7 of
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`the Complaint.
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`8.
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`Samsung admits that SEA merged with Samsung Telecommunications America
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`LLC (“STA”) in January 2015. Samsung admits that STA was involved in the sales and
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`2
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`distribution of certain Samsung-branded mobile electronic products in the United States. Samsung
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`denies that STA or any other Samsung entity infringed any of the Asserted Patents. Samsung
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`denies the remaining allegations in Paragraph 8 of the Complaint.
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`9.
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`Samsung denies that SEA or STA has committed any acts of infringement as
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`alleged by Caltech. Samsung further denies that any alleged acts of infringement at issue in this
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`case occurred before the merger of STA and SEA, which occurred more than six years before the
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`Complaint was filed. The remaining allegations in Paragraph 9 of the Complaint express legal
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`conclusions and thus no response is required. To the extent that a response is required, Samsung
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`denies the remaining allegations in Paragraph 9 of the Complaint.
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`10.
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`Samsung denies the allegations in Paragraph 10 of the Complaint.
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`JURISDICTION AND VENUE
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`11.
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`Samsung admits that the Complaint purports to set forth an action under the patent
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`laws of the United States, Title 35 of the United States Code.
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`12.
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`As pled, Samsung does not deny that the Court has jurisdiction under 28 U.S.C. §§
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`1331 and 1338(a). Samsung denies the Court has subject matter jurisdiction in this case, and on
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`that basis denies the remaining allegations in Paragraph 12 of the Complaint.
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`13.
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`For the purposes of this action only, Samsung does not challenge personal
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`jurisdiction in the Eastern District of Texas. Samsung denies that it has committed any acts of
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`infringement as alleged by Caltech. The remaining allegations in Paragraph 13 of the Complaint
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`express legal conclusions and thus no response is required. To the extent that a response is
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`required, Samsung denies the remaining allegations in Paragraph 13 of the Complaint.
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`14.
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`Samsung admits that SEA has offices in the Eastern District of Texas, including at
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`6625 Excellence Way, Plano, Texas 75023. The remaining allegations in Paragraph 14 of the
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`3
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`Complaint express legal conclusions and thus no response is required. To the extent that a response
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`is required, Samsung denies the remaining allegations in Paragraph 14 of the Complaint.
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`15.
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`Samsung admits that the website cited in Paragraph 15 Footnote 1 of the Complaint,
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`when accessed on April 5, 2022, stated that SEA’s “Mobile hub in Plano centralizes innovation
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`and enhances cross-functional collaboration for all teams dedicated to their largest mobile product
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`line: smartphones” and its “[d]ivisions includ[e] Networks, Mobile Marketing, Computing and
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`Wearables, and Product Management.” Samsung further admits that the April 6, 2018 website
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`cited in Paragraph 15 Footnote 2 of the Complaint, when accessed on April 5, 2022, stated that as
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`of the date of that article, “Samsung Electronics America’s North Texas offices will now be located
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`in a newly redeveloped 216,000 square foot building” and “more than 1,000 regional employees
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`from two current locations in Richardson and Plano will be relocated to the new location.”
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`Samsung denies the remaining allegations in Paragraph 15 of the Complaint.
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`16.
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`17.
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`18.
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`Samsung denies the allegations in Paragraph 16 of the Complaint.
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`Samsung denies the allegations in Paragraph 17 of the Complaint.
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`For the purposes of this action only, Samsung does not contest that the requirements
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`of 28 U.S.C. § 1391(b)-(c) and 28 U.S.C. § 1400 are satisfied, as pled. Samsung denies that venue
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`is proper and denies that this District is the most convenient venue under 28 U.S.C. § 1404.
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`19.
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`Samsung admits that SEC is a corporation organized and existing under the laws of
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`the Republic of Korea. Samsung further admits that SEA has offices at 6625 Excellence Way,
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`Plano, Texas 75023. The remaining allegations in Paragraph 19 of the Complaint express legal
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`conclusions and thus no response is required. To the extent that a response is required, Samsung
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`denies the remaining allegations in Paragraph 19 of the Complaint.
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`4
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`ASSERTED PATENTS
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`20.
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`Samsung admits that what is purported to be a copy of the ’710 patent is attached
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`to the Complaint as Exhibit A. Samsung admits that, on its face, the ’710 patent is titled “Serial
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`Concatenation of Interleaved Convolutional Codes Forming Turbo-Like Codes” and states the date
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`of the patent is October 3, 2006. The ’710 patent purports to be a continuation-in-part to U.S.
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`Patent Application No. 09/922,852.
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`21.
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`Samsung admits that what is purported to be a copy of the ’032 patent is attached
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`to the Complaint as Exhibit B. Samsung admits that, on its face, the ’032 patent is titled “Serial
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`Concatenation of Interleaved Convolutional Codes Forming Turbo-Like Codes” and states the date
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`of the patent is September 2, 2008. Samsung admits that the ’032 patent states that it is a
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`continuation of the application that led to the ’710 patent and purports to be a continuation-in-part
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`to U.S. Patent Application No. 09/922,852.
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`22.
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`Samsung admits that what is purported to be a copy of the ’552 patent is attached
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`to the Complaint as Exhibit C. Samsung admits that, on its face, the ’552 patent is titled
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`“Interleaved Serial Concatenation Forming Turbo-Like Codes” and states the date of the patent is
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`May 11, 2010. The ’552 patent purports to be a continuation of U.S. Patent Application No.
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`09/922,852.
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`23.
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`Samsung admits that what is purported to be a copy of the ’781 patent is attached
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`to the Complaint as Exhibit D. Samsung admits that, on its face, the ’781 patent is titled “Serial
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`Concatenation of Interleaved Convolutional Codes Forming Turbo-Like Codes” and states the date
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`of the patent is March 29, 2011. Samsung admits that the ’781 patent states that it is a continuation
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`of the application that led to the ’032 patent, which is a continuation of the application that led to
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`the ’710 patent and purports to be a continuation-in-part to U.S. Patent Application No.
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`09/922,852.
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`5
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`24.
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`Samsung admits that what is purported to be a copy of the ’833 patent is attached
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`to the Complaint as Exhibit E. Samsung admits that, on its face, the ’833 patent is titled “Serial
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`Concatenation of Interleaved Convolutional Codes Forming Turbo-Like Codes” and states the date
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`of the patent is October 9, 2012. Samsung admits that the ’833 patent states that it is a continuation
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`of the application that led to the ’781 patent, which is a continuation of the application that led to
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`the ’032 patent, which is a continuation of the application that led to the ’710 patent and purports
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`to be a continuation-in-part to U.S. Patent Application No. 09/922,852.
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`25.
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`Samsung admits that, on its face, each of the ’710, ’032, ’781, and ’833 patents
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`purports to identify Hui Jin, Aamod Khandekar, and Robert J. McEliece as inventors.
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`26.
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`Samsung admits that, on its face, the ’552 patent purports to identify Dariush
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`Divsalar, Robert J. McEliece, Hui Jin, and Fabrizio Pollara as inventors.
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`27. Samsung admits that the ’710, ’032, ’781, and ’833 patents expired on or before
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`August 18, 2020. Samsung admits that the ’552 patent expired on or before January 4, 2022.
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`Samsung denies the remaining allegations in Paragraph 27 of the Complaint.
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`28.
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`Samsung denies the allegations in Paragraph 28 of the Complaint.
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`BACKGROUND
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`29.
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`Samsung denies that the Asserted Patents “disclose a seminal improvement to
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`coding systems and methods.” Samsung further denies that the ’552 Patent (“RA Patent”) is
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`directed to “a new class of error correction codes” and that the ’710, ’032, ’781, and ’833 patents
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`(“IRA Patents”) “introduce another new class of error correction codes.” Samsung disagrees with
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`Caltech’s characterization of the technology, and therefore denies the allegations of Paragraph 29.
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`To the extent Paragraph 29 makes allegations regarding the alleged invention and scope of the
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`claims, Samsung denies such allegations. Samsung’s responses are not intended to interpret the
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`6
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`meaning or scope of the claims of the Asserted Patents. The remaining allegations in Paragraph
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`29 of the Complaint express legal conclusions about the alleged invention and scope of the claims
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`and thus no response is required. To the extent that a response is required, Samsung denies the
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`remaining allegations in Paragraph 29 of the Complaint.
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`30.
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`Samsung disagrees with Caltech’s characterization of the technology, and therefore
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`denies the allegations of Paragraph 30. Samsung denies that “the IRA Patents enable a person of
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`ordinary skill in the art to implement IRA codes using simple circuitry, providing improved
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`performance over prior art encoders and decoders.” To the extent Paragraph 30 makes allegations
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`regarding the alleged invention and scope of the claims, Samsung denies such allegations.
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`Samsung’s responses are not intended to interpret the meaning or scope of the claims of the
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`Asserted Patents. To the extent Paragraph 30 purports to contain any other or different allegations,
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`Samsung denies them.
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`31.
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`Samsung admits that what is purported to be a copy of a paper titled “Irregular
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`Repeat-Accumulate Codes” is attached to the Complaint as Exhibit F. Samsung admits that, on
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`its face, Exhibit F identifies Hui Jin, Aamod Khandekar, and Robert McEliece as authors.
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`Samsung admits that Exhibit F states that “[t]his paper is to be presented at the Second
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`International Conference on Turbo Codes, Brest, France, September 2000.” Samsung denies the
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`remaining allegations in Paragraph 31 of the Complaint.
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`32.
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`Samsung admits that what is purported to be a copy of a paper titled “Design
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`Methods for Irregular Repeat-Accumulate Codes” is attached to the Complaint as Exhibit G.
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`Samsung admits the paper identifies Aline Roumy, Souad Guemghar, Giuseppe Caire, and Sergio
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`Verdú and includes the quote “IEEE Transactions on Information Theory, Vol. 50, No. 8, August
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`2004.” Samsung further admits Exhibit G includes the block quoted language in Paragraph 32 of
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`the Complaint. Samsung denies the remaining allegations in Paragraph 32 of the Complaint.
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`33.
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`Samsung admits the IEEE has developed standards for wireless communications
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`over local area networks and that certain of those standards are sometimes referred to as “Wi-Fi.”
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`Samsung further admits certain modem electronic products, including certain smartphones,
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`laptops, routers, televisions, cameras, cars, and other devices that have wireless connections use
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`Wi-Fi. Samsung disagrees with Caltech’s characterization of the technology, and therefore denies
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`the remaining allegations of Paragraph 33.
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`34.
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`Samsung admits the 802.11 standardization process began in the 1990s and the first
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`version of 802.11 was referred to as IEEE 802.11-1997 and that in the following years, subsequent
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`versions of the 802.11 standard were adopted. Samsung disagrees with Caltech’s characterization
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`of the technology, and therefore denies the remaining allegations of Paragraph 34.
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`35.
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`Samsung disagrees with Caltech’s characterization of the technology, and therefore
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`denies the allegations of Paragraph 35. To the extent Paragraph 35 makes allegations regarding
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`the alleged invention and scope of the claims, Samsung denies such allegations. Samsung’s
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`responses are not intended to interpret the meaning or scope of the claims of the Asserted Patents.
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`To the extent Paragraph 35 purports to contain any other or different allegations, Samsung denies
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`the allegations in Paragraph 35 of the Complaint.
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`36.
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`Samsung admits that in May 2016, Caltech filed a patent infringement action
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`against Apple and Broadcom in the Central District of California involving the ’710, ’032, ’781,
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`and ’833 patents. Samsung admits that the document in Caltech v. Broadcom Ltd., et al., No. 16-
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`cv-3714-GW, Dkt. No. 2114 (C.D. Cal. Jan. 29, 2020) purports to be a Verdict Form. Samsung
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`admits that a jury found Apple and Broadcom infringed certain claims of the ’710, ’032, and ’781
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`patents and awarded Caltech more than $1 billion in damages, but the Federal Circuit vacated the
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`8
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`judgment of infringement for the ’781 patent and the damages award in its entirety and then
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`remanded for a new trial. California Inst. of Tech. v. Broadcom Ltd., 25 F.4th 976, 980 (Fed. Cir.
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`2022). Samsung denies committing any acts of infringement at any time, including at least because
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`Samsung products do not infringe the Asserted Patents and Samsung is licensed to the Asserted
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`Patents. Samsung denies any remaining allegations in Paragraph 36 of the Complaint.
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`37.
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`Samsung lacks knowledge or information sufficient to form a belief as to the truth
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`of the allegations in Paragraph 37 of the Complaint and, on that basis, denies them.
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`38.
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`Samsung admits Apple filed ten IPR petitions with the United States Patent and
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`Trademark Office’s Patent Trial and Appeal Board (“PTAB”) seeking to invalidate the ’710, ’032,
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`’781, and ’833 patents. Samsung admits the PTAB denied institution of three of those petitions.
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`Samsung denies that the PTAB upheld the patentability for all claims, at least because the PTAB
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`did not consider all claims of the ’710, ’032, ’781, and ’833 patents and because it held claims 19-
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`21 of the ’781 patent were unpatentable. Samsung denies any remaining allegations in Paragraph
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`38 of the Complaint.
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`39.
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`40.
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`Samsung denies the allegations in Paragraph 39 of the Complaint.
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`Samsung admits that at least some documents for at least some of the models of the
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`products identified in Paragraph 39 of the Complaint reference the 802.11n, 802.11ac, and/or
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`802.11ax standards, but denies that Caltech has asserted any of the Asserted Patents are essential
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`to practicing these standards. Samsung further admits that at least some third-party documents for
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`at least some of the models of the products identified in Paragraph 39 of the Complaint reference
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`LDPC codes. Samsung denies the remaining allegations in Paragraph 40 of the Complaint.
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`41.
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`Samsung admits that at least some third-party documents for at least some of the
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`models of the products identified in Paragraph 39 of the Complaint reference LDPC codes.
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`Samsung denies the remaining allegations in Paragraph 41 of the Complaint.
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`42.
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`Samsung admits that the third-party website cited in Paragraph 42 Footnote 3 of
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`the Complaint, when accessed on April 5, 2022, purported to describe specifications for
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`QCA6174A, and included the quoted language “2x2 dual-band 802.11ac Wi-Fi with MU-MIMO.”
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`Samsung admits that the third-party website cited in Paragraph 42 Footnote 3 of the Complaint,
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`when accessed on April 5, 2022, included the quoted language “Standards: 802.11ac Wave 2,
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`802.11a/b/g, 802.11n” under “Specifications” for “Wi-Fi,” and “Maximal Likelihood (ML)
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`decoding, lowdensity parity check (LDPC), maximum ratio combining (MRC) for robust link
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`connection” under “Features.” Samsung denies that the third-party website cited in Paragraph 42
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`Footnote 3 of the Complaint, when accessed on April 5, 2022, referred to the Samsung Galaxy
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`Tab S3 or included the language “QCA6174A 2x2 MU-MIMO 11ac Wi-Fi technology.” Samsung
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`denies the remaining allegations in Paragraph 42 of the Complaint.
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`43.
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`Samsung admits that the third-party website cited in Paragraph 43 Footnote 4 of
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`the Complaint, when accessed on April 5, 2022, purported to be a teardown report of a Samsung
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`Galaxy S4 product on or before April 27, 2013, which is more than six years before the Complaint
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`was filed. Samsung admits that the third-party website cited in Paragraph 43 Footnote 4 of the
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`Complaint, when accessed on April 5, 2022, purported to show “Broadcom BCM4335 Single-
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`Chip 5G Wi-Fi MAC/Baseband/Radio.” The third-party website cited in Paragraph 43 Footnote
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`5 of the Complaint, when accessed on April 5, 2022, did not refer to BCM4335, and on that basis,
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`Samsung denies allegations regarding what the third-party website cited in Paragraph 43 Footnote
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`5 of the Complaint, when accessed on April 5, 2022, shows. Samsung denies the remaining
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`allegations in Paragraph 43 of the Complaint.
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`44.
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`Samsung admits that the third-party website cited in Paragraph 44 Footnote 6 of
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`the Complaint, when accessed on April 5, 2022, purported to be a review of the Samsung Galaxy
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`S5 LTE-A on or before August 5, 2014, which is more than six years before the Complaint was
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`filed, and included the term “a Qualcomm Atheros QCA6174 solution.” Samsung lacks
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`knowledge or information sufficient to form a belief as to the truth of the remaining allegations in
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`paragraph 44 of the Complaint and, on that basis, denies them.
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`45.
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`Samsung admits that the third-party website cited in Paragraph 45 Footnote 7 of
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`the Complaint, when accessed on April 5, 2022, purported to be a teardown report for a Samsung
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`SM-G930FD Galaxy S7 smartphone on or before August 6, 2016 and purported to show a
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`“Broadcom BCM4359 (Die) 5G Wi-Fi Combo Chip” purportedly found inside the Samsung
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`4541S7 components extracted from the Samsung SM-G930FD Galaxy S7 smartphone. Samsung
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`admits that the third-party website cited in Paragraph 45 Footnote 8 of the Complaint dated March
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`2, 2015, when accessed on April 5, 2022, stated: “The BCM4359 is Broadcom’s 2x2 MIMO 5G
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`WiFi combo chip with Bluetooth 4.1 and FM radio featuring:” “2x2 HT80 802.11ac” and
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`“Transmit beamforming and Low Density Parity Check (LDPC).” Samsung denies the remaining
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`allegations in Paragraph 45 of the Complaint.
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`46.
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`Samsung denies the third-party website cited in Paragraph 46 Footnote 9 of the
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`Complaint, when accessed on April 5, 2022, is a teardown report for the Samsung Galaxy S10 that
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`shows a Broadcom BCM4375 Wi-Fi module inside a smartphone. Samsung admits that the third-
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`party website cited in Paragraph 46 Footnote 10 of the Complaint, when accessed on April 5, 2022,
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`included under “Features” of the chip, stated “Support for two streams of 802.11ax” and “1024
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`QAM modulation.” Samsung admits IEEE 802.11ax-2021 at § 27.1.1 included the quoted
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`language “LDPC coding (transmit and receive) in all supported HE PPDU types, RU sizes, and
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`number of spatial streams if the STA declares support for HE-MCSs 10 and 11 (transmit and
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`receive).” Samsung disagrees with Caltech’s characterization of the technology, and therefore
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`denies the remaining allegations of Paragraph 46.
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`47.
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`Samsung admits that at least some certifications for some of the models of the
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`products identified in Paragraph 39 of the Complaint state those specific products comply with the
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`802.11ac and/or 802.11ax standards. Samsung admits that at least some of the models of the
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`products identified in Paragraph 39 of the Complaint have received a “Wi-Fi CERTIFIED”
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`designation from the Wi-Fi Alliance. Samsung admits that quotes in this paragraph that are alleged
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`to be found on cited Wi-Fi Alliance webpages were found on those webpages at least as of April
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`5, 2022. Samsung admits that the third-party website cited in Paragraph 47 Footnote 12, when
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`accessed on April 5, 2022, stated on its face the principal office of the Wi-Fi Alliance was 10900-
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`A Stonelake Boulevard Suite 195, Austin, TX 78759 USA and that it included the quoted language
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`“the specific purpose of the corporation is to promote multi-vendor interoperability for markets
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`including the enterprise, small office, and home and in particular the development, adoption and
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`use of Wi-Fi technology and products and services relating thereto.” Samsung admits SEC became
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`a Sponsor member of the Wi-Fi Alliance in 2011. Samsung admits that, as one of the sponsor
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`members, it is permitted to designate a director and an alternate director to serve on the Board.
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`Samsung admits that the third-party website cited in Paragraph 47, Footnote 14, when accessed on
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`April 5, 2022, stated on its face that “Wi-Fi CERTIFIEDTM” “indicat[es] that they have met
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`industry-agreed standards for interoperability, security, and a range of application specific
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`protocols.” Samsung admits that the third-party website cited in Paragraph 47, Footnote 15, when
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`accessed on April 5, 2022, on its face, stated that “Wi-Fi CERTIFIED 6” is a “certification program
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`based on the IEEE 802.1lax standard.” Samsung admits that the third-party website cited in
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`Paragraph 47 Footnote 16, when accessed on April 5, 2022, on its face, stated that “Wi-Fi
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`CERTIFIED ac” is “[b]ased on IEEE 802.11ac.” Samsung admits that a certification issued under
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`the “Wi-Fi CERTIFIED 6” and “Wi-Fi CERTIFIED ac” programs may include information
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`regarding LDPC codes. To the extent there are any remaining allegations, Samsung denies the
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`remaining allegations in Paragraph 47 of the Complaint.
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`48.
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`Samsung admits that the third-party website cited in Paragraph 48 Footnote 17 of
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`the Complaint, when accessed on April 5, 2022, purported to be a certification identifying a date
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`of June 16, 2020 for the SM-F707U product. Samsung admits the third-party website when
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`accessed on April 5, 2022 included the terms “Wi-Fi CERTIFIED 6™” and “Wi-Fi CERTIFIED™
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`ac.” Samsung further admits the third-party website when accessed on April 5, 2022 included the
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`language “LDPC Rx” and “LDPC Tx” under the “Wi-Fi CERTIFIED 6™” and “Wi-Fi
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`CERTIFIED™ ac” headings on the final page. To the extent there are any remaining allegations,
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`Samsung denies the remaining allegations in Paragraph 48 of the Complaint.
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`49.
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`Samsung admits that the third-party website cited in Paragraph 49 Footnote 18 of
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`the Complaint, when accessed on April 5, 2022 purported to be a certification identifying a date
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`of September 4, 2019 for the SM-N976U product. Samsung admits the third-party website cited
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`in Paragraph 49 Footnote 18 of the Complaint, when accessed on April 5, 2022, included the terms
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`“Wi-Fi CERTIFIED 6™” and “Wi-Fi CERTIFIED™ ac.” Samsung further admits the third-party
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`website cited in Paragraph 49 Footnote 18 of the Complaint, when accessed on April 5, 2022,
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`included the language “LDPC Rx” and “LDPC Tx” under the “Wi-Fi CERTIFIED 6™” and “Wi-
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`Fi CERTIFIED™ ac” headings on the fourth page. To the extent there are any remaining
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`allegations, Samsung denies the remaining allegations in Paragraph 49 of the Complaint.
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`COUNT ONE
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`50.
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`Paragraph 50 of the Complaint does not require an answer. To the extent any
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`response is required, Samsung repeats and incorporates by reference the responses to Paragraphs
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`1–49 as if fully set forth herein.
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`51.
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`Samsung denies the allegations in Paragraph 51 of the Complaint.
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`Case 2:21-cv-00446-JRG Document 19 Filed 04/05/22 Page 15 of 32 PageID #: 221
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`52.
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`Samsung admits that at least some documents for at least some of the models of the
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`products identified in Paragraph 39 of the Complaint reference the 802.11n, 802.11ac, and/or
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`802.11ax standards. Samsung further admits that at least some third-party documents for at least
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`some of the models of the products identified in Paragraph 39 of the Complaint reference LDPC
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`codes. Samsung denies that it has committed any acts of infringement as alleged by Caltech,
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`including because Samsung products do not infringe the Asserted Patents and because Samsung
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`has a license to the ’710 patent. Samsung disagrees with Caltech’s characterization of the
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`technology, and therefore denies the allegations of Paragraph 52. To the extent Paragraph 52
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`makes allegations regarding the alleged invention and scope of the claims, Samsung denies such
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`allegations. Samsung’s responses are not intended to interpret the meaning or scope of the claims
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`of the Asserted Patents. Samsung denies any remaining allegations in Paragraph 52 of the
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`Complaint.
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`53.
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`Samsung admits that the image of a table shown in Paragraph 53 can be found in
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`IEEE 802.11n-2009 at § 20.3.11.6.2, IEEE 802.11-2012 at § 20.3.11.7.2; IEEE 802.11-2016 at §
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`19.3.11.7.2; and IEEE 802.11-2020 at § 19.3.11.7.2. To the extent Paragraph 53 makes allegations
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`regarding the alleged invention and scope of the claims, Samsung denies such allegations.
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`Samsung’s responses are not intended to interpret the meaning or scope of the claims of the
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`Asserted Patents. Samsung denies the remaining allegations or characterizations in Paragraph 53
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`of the Complaint.
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`54.
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`Samsung admits that the image included in Paragraph 54 of the Complaint can be
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`found in IEEE 802.11n-2009 at § 20.3.11.6.3. Samsung admits that at least some third-party
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`documents for at least some models of the products identified in Paragraph 39 of the Complaint
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`reference LDPC codes. To the extent Paragraph 54 makes allegations regarding the alleged
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`invention and scope of the claims, Samsung denies such allegations. Samsung’s responses are not
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`intended to interpret the meaning or scope of the claims of the Asserted Patents. Samsung denies
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`the remaining allegations or characterizations in Paragraph 54 of the Complaint.
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`55.
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`Samsung admits that the image shown in Paragraph 55 is an excerpt of a larger
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`table that can be found in IEEE 802.11n-2009 at Annex R, Table R.1, but denies that the red line
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`embedded in the table appears in IEEE 802.11n-2009 at Annex R, Table R.1. To the extent
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`Paragraph 55 makes allegations regarding the alleged invention and scope of the claims, Samsung
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`denies such allegations. Samsung’s responses are not intended to interpret the meaning or scope
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`of the claims of the Asserted Patents. Samsung denies the remaining allegations or
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`characterizations in Paragraph 55 of the Complaint.
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`56.
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`57.
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`58.
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`59.
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`Samsung denies the allegations contained in Paragraph 56 of the Complaint.
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`Samsung denies the allegations contained in Paragraph 57 of the Complaint.
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`Samsung denies the allegations contained in Paragraph 58 of the Complaint.
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`Samsung is licensed to the ’710 patent, and thus denies the allegations in Paragraph
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`59 of the Complaint. Samsung further denies that Samsung practices the claims of the ’710 patent.
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`60.
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`61.
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`Samsung denies the allegations contained in Paragraph 60 of the Complaint.
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`Samsung denies the allegations contained in Paragraph 61 of the Complaint, at least
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`because Samsung has not committed any wrongful acts as alleged by Caltech and Caltech has not
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`sustained any damages. Samsung further denies the allegations contained in Paragraph 61 of the
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`Complaint, at least because Samsung has a license to the ’710 patent and because Caltech is not
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`entitled to pre-suit damages. Samsung denies the remaining allegations or characterizations in
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`Paragraph 61 of the Complaint.
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`62.
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`Samsung denies the allegations contained in Paragraph 62 of the Complaint.
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`15
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