Case 2:22-cv-00185-JRG Document 34 Filed 09/14/22 Page 1 of 24 PageID #: 511
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`DEFENDANTS’ ANSWER TO PLAINTIFF’S FIRST AMENDED COMPLAINT
`FOR PATENT INFRINGEMENT
`
`
`
`Case No. 2:22-cv-00185-JRG
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`Plaintiff,
`
`v.
`
`VERIZON COMMUNICATIONS INC.
`CELLCO PARTNERSHIP, d/b/a
`VERIZON WIRELESS, VERIZON
`ENTERPRISE SOLUTIONS, LLC,
`VERIZON BUSINESS GLOBAL LLC,
`VERIZON BUSINESS NETWORK
`SERVICES, LLC and TERREMARK
`NORTH AMERICA LLC,
`
`
`
`Defendants.
`
`Defendants Verizon Communications Inc., Cellco Partnership, d/b/a Verizon Wireless,
`
`Verizon Enterprise Solutions, LLC, Verizon Business Global LLC, Verizon Business Network
`
`Services, LLC, and Terremark North America, Inc. (collectively, “Defendants” or “Verizon”)
`
`hereby answer the First Amended Complaint for Patent Infringement filed by Plaintiff AGIS
`
`Software Development LLC (“AGIS”). Verizon specifically denies the allegations not expressly
`
`admitted below.
`
`THE PARTIES1
`
`1.
`
`Verizon is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in paragraph 1, and therefore denies them.
`
`
`1
`Multiple defendants are incorrectly named in the First Amended Complaint and Verizon
`Enterprise Solutions LLC is no longer an active entity.
`
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`

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`Case 2:22-cv-00185-JRG Document 34 Filed 09/14/22 Page 2 of 24 PageID #: 512
`
`2.
`
`Verizon admits the allegations in paragraph 2, except that it specifically denies that
`
`jurisdiction in this case is proper over Verizon Communications Inc. and that Verizon
`
`Communications Inc. may be served with process through its registered agent at CT Corporation
`
`System, 350 North Street, Dallas, Texas 75201.
`
`3.
`
`Verizon admits the allegations in paragraph 3 as to Cellco Partnership d/b/a Verizon
`
`Wireless (“VZW”).
`
`4.
`
`Verizon denies the allegations in paragraph 4. Verizon Enterprise Solutions LLC is
`
`not an active entity.
`
`5.
`
`6.
`
`Verizon admits the allegations in paragraph 5.
`
`Verizon admits that Verizon Business Network Services LLC is a corporation
`
`organized under the laws of the State of Delaware. Verizon otherwise denies the remaining
`
`allegations in paragraph 5.
`
`7.
`
`Verizon admits that Terremark North America LLC is a Florida limited liability
`
`company and that it has a principal place of business at One Verizon Way, Basking Ridge, New
`
`Jersey 07920. Except as expressly admitted, Verizon denies the remaining allegations in paragraph
`
`7.
`
`8.
`
`To the extent that the allegations of paragraph 8 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 8, including it
`
`specifically denies having conducted business in the Eastern District of Texas and denies that it is
`
`subject to personal jurisdiction in this District. Verizon denies that the retail locations identified in
`
`this paragraph are related to the allegations in the Complaint.
`
`9.
`
`Verizon otherwise denies the allegations in paragraph 9.
`
`
`DM2\16304470.2
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`2
`
`

`

`Case 2:22-cv-00185-JRG Document 34 Filed 09/14/22 Page 3 of 24 PageID #: 513
`
`10.
`
`Verizon admits that Verizon Network Services Inc., Terremark North America
`
`LLC, and Verizon Business Global LLC are directly or indirectly, wholly-owned by Verizon
`
`Communications Inc. Except as expressly admitted, Verizon denies the remaining allegations in
`
`paragraph 10.
`
`JURISDICTION AND VENUE
`
`11.
`
`Verizon admits that the First Amended Complaint purports to bring an action that
`
`arises under the patent laws of the United States, 35 U.S.C. §§ 1 et seq., but denies that Verizon
`
`has committed any act of patent infringement. To the extent the allegations in paragraph 11 call
`
`for a legal conclusion, no response is required. To the extent a response is required, for purposes
`
`of this action only, Verizon admits that this Court has subject matter jurisdiction.
`
`12.
`
` To the extent the allegations in paragraph 12 call for a legal conclusion, no
`
`response is required. Verizon denies any remaining allegations of paragraph 12 including
`
`specifically that all Defendants (collectively as alleged) are subject to personal jurisdiction in this
`
`District.
`
`13.
`
`Verizon denies that venue is permissible or proper with respect to all Defendants
`
`except for VZW in the Eastern District of Texas. Verizon denies all remaining allegations in
`
`paragraph 13.
`
`PATENTS-IN-SUIT
`
`14.
`
`Verizon admits that U.S. Patent No. 8,213,970 (the “’970 Patent”) appears to be
`
`issued by the United States Patent and Trademark Office on July 3, 2012. Verizon admits that the
`
`’970 Patent
`
`is entitled “Method of Utilizing Forced Alerts for Interactive Remote
`
`Communications.” Verizon admits that Exhibit A to the First Amended Complaint appears to be a
`
`copy of the ’970 Patent and September 1, 2021 Inter Partes Review Certificate and December 9,
`
`2021 Ex Parte Reexamination Certificate. Verizon admits that the copy of the September 1, 2021
`
`
`DM2\16304470.2
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`3
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`

`

`Case 2:22-cv-00185-JRG Document 34 Filed 09/14/22 Page 4 of 24 PageID #: 514
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`Inter Partes Review Certificate attached as Exhibit A states that “Claims 1 and 3-9 and cancelled.”
`
`Verizon admits that the copy of the December 9, 2021 Ex Parte Reexamination Certificate attached
`
`as Exhibit A states that claims 2 and 10 “are determined to be patentable as amended” and claims
`
`11-13, “dependent on an amended claim, are determined to be patentable.” Verizon denies any
`
`remaining allegations.
`
`15.
`
`Verizon admits that U.S. Patent No. 9,467,838 (the “’838 Patent”) appears to be
`
`issued by the United States Patent and Trademark Office on October 11, 2016. Verizon admits that
`
`the ’838 Patent is entitled “Method to Provide Ad Hoc and Password Protected Digital and Voice
`
`Networks.” Verizon admits that Exhibit B to the First Amended Complaint appears to be a copy
`
`of the ’838 Patent and May 27, 2021 Ex Parte Reexamination Certificate. Verizon admits that the
`
`copy of the May 27, 2021 Ex Parte Reexamination Certificate states “[t]he patentability of claims
`
`1-84 is confirmed.” Verizon denies any remaining allegations.
`
`16.
`
`Verizon admits that U.S. Patent No. 9,749,829 (the “’829 Patent”) appears to be
`
`issued by the United States Patent and Trademark Office on August 29, 2017. Verizon admits that
`
`the ’829 Patent is entitled “Method to Provide Ad Hoc and Password Protected Digital and Voice
`
`Networks.” Verizon admits that Exhibit C to the First Amended Complaint appears to be a copy
`
`of the ’829 Patent and August 16, 2021 Ex Parte Reexamination Certificate. Verizon admits that
`
`the copy of the August 16, 2021 Ex Parte Reexamination Certificate states “[t]he patentability of
`
`claims 1-68 is confirmed.” Verizon denies any remaining allegations.
`
`17.
`
`Verizon admits that U.S. Patent No. 9,820,123 (the “’123 Patent”) appears to be
`
`issued by the United States Patent and Trademark Office on November 14, 2017. Verizon admits
`
`that the ’123 Patent is entitled “Method to Provide Ad Hoc and Password Protected Digital and
`
`Voice Networks.” Verizon admits that Exhibit D to the First Amended Complaint appears to be a
`
`
`DM2\16304470.2
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`4
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`

`

`Case 2:22-cv-00185-JRG Document 34 Filed 09/14/22 Page 5 of 24 PageID #: 515
`
`copy of the ’123 Patent and September 24, 2021 Ex Parte Reexamination Certificate. Verizon
`
`admits that the copy of the September 24, 2021 Ex Parte Reexamination Certificate states “[t]he
`
`patentability of claims 1-48 is confirmed.” Verizon denies any remaining allegations.
`
`18.
`
`Verizon is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations of Paragraph 18 and therefore, denies them.
`
`FACTUAL ALLEGATIONS2
`
`19.
`
`Verizon is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in paragraph 19, and therefore denies them.
`
`20.
`
`Verizon is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in paragraph 20, and therefore denies them.
`
`21.
`
`22.
`
`23.
`
`24.
`
`Verizon denies the allegations in paragraph 21.
`
`Verizon denies the allegations in paragraph 22.
`
`Verizon denies the allegations in paragraph 23.
`
`Verizon admits that some Verizon products include functionalities that allow users
`
`to interact with each other and display maps. To the extent paragraph 24 purports to include
`
`screenshots from https://www.verizon.com/business/solutions/public-sector/public-safety/first-
`
`responder-applications/#video-2,
`
`https://www.verizon/com/busines/solutions/public-
`
`sector/public-safety/first-responder-applications/#video-3,
`
`https://www.verizon.com/business/solutions/public-sector/public-safety/first-responder-
`
`applications/#video-4,
`
`https://www.verizon.com/business/solutions/public-sector/public-
`
`safety/first-responder-applications/#video-8,
`
`
`2
`For convenience and clarity, Verizon’s Answer repeats the same headings used in the First
`Amended Complaint. In so doing, Verizon does not admit any allegations contained in those
`headings.
`
`
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`5
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`Case 2:22-cv-00185-JRG Document 34 Filed 09/14/22 Page 6 of 24 PageID #: 516
`
`https://www.verizon.com/business/products/internet-of-things/connected-smart-cities-
`
`communities/real-time-response-system/, Verizon denies those screenshots are from these
`
`websites.3 To
`
`the
`
`extent paragraph 24 purports
`
`to
`
`include
`
`screenshots
`
`from
`
`https://www.youtube.com/watch?v=mqkL6vCC018,
`
`https://www.youtube.com/watch?v=bvvqpe9fkzs&t=2s,
`
`https://www.youtube.com/watch?v=3T_g6qnwV1Q&t=322s,
`
`https://www.youtube.com/watch?v=-nWcnt91sCM&t=181s,
`
`https://www.youtube.com/watch?v=2_p-XWcv-7s&t=7s, Verizon admits that the videos include
`
`those screenshots at the times stamped. To the extent paragraph 24 purports to include excerpts
`
`from
`
`https://www.verizon.com/business/resources/solutionsbriefs/2020/unifying_data_helps_you_mak
`
`e_better_faster_decisions.pdf
`
`and
`
`https://www.verizonconnect.com/solutions/field-service-
`
`management-software/real-time-eta/ Verizon denies there is any excerpt to this document in
`
`paragraph 24. To
`
`the extent paragraph 24 purports
`
`to
`
`include screenshots
`
`from
`
`https://www.verizonconnect.com, https://www.verizonconnect.com/features/near-real-time-gps-
`
`tracking/, and https://www.verizon/connect.com/solutions/field-service-management-software/
`
`Verizon admits that the images appear at those sites. Except as expressly admitted, Verizon denies
`
`the remaining allegations in paragraph 24.
`
`
`3 Plaintiff’s First Amended Complaint cites to numerous web addresses without providing any
`date on which the web address was allegedly visited or providing copies of the visited web pages
`as exhibits. See Dkt. 23 at ¶¶ 24, 32, 43, 59, 75. Verizon’s responses herein to characterizations
`of the content of those web addresses is based on visiting the cited address on August 30, 2022.
`
`
`DM2\16304470.2
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`6
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`

`

`Case 2:22-cv-00185-JRG Document 34 Filed 09/14/22 Page 7 of 24 PageID #: 517
`
`COUNT I (Infringement of the ’970 Patent)
`
`25.
`
`Verizon incorporates by reference paragraphs 1 through 24 as if fully restated
`
`herein.
`
`26.
`
`Verizon is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in paragraph 26, and therefore denies them.
`
`27.
`
`To the extent that the allegations of paragraph 27 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 27 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’970 Patent.
`
`28.
`
`To the extent that the allegations of paragraph 28 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 28 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’970 Patent.
`
`29.
`
`To the extent that the allegations of paragraph 29 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 29 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’970 Patent.
`
`30.
`
`To the extent that the allegations of paragraph 30 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 30 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’970 Patent.
`
`31.
`
`To the extent that the allegations of paragraph 31 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 31 including
`
`
`DM2\16304470.2
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`7
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`

`

`Case 2:22-cv-00185-JRG Document 34 Filed 09/14/22 Page 8 of 24 PageID #: 518
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’970 Patent.
`
`32.
`
`To the extent that the allegations of paragraph 32 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 32 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’970 Patent. To the extent paragraph 32 purports to include screenshots from https://reveal-
`
`help.verizonconnect.com/hc/en-us/articles/360010671999-Log-in-to-Reveal,
`
`https://reveal-
`
`help.verizonconnect.com/hc/en-us/articles/360011079099-Reveal-mobile-apps,
`
`https://reveal-
`
`help.verizonconnect.com/hc/en-us/articles/360010589240-Creating-and-editing-groups,
`
`https://reveal-help.verizonconnect.com/hc/en-us/articles/360010567759-Using-the-Live-Map,
`
`https://reveal-help.verizonconnect.com/hc/en-us/articles/360010455560-See-vehicles-on-Live-
`
`Map,
`
`https://reveal-help.verizonconnect.com/hc/en-us/articles/360010567839-Fleet-Status-list,
`
`https://reveal-help.verizonconnect.com/hc/en-us/articles/360010567879-See-your-fleet-status-
`
`on-Live-Map,
`
` https://reveal-help.verizonconnect.com/hc/en-us/articles/360010454660-Find-
`
`nearest-vehicle-or-asset, https://reveal-help.verizonconnect.com/hc/en-us/articles/360010497980-
`
`Creating-Places, and https://reveal-help.verizonconnect.com/hc/en-us/articles/360010567919-
`
`View-job-details, Verizon admits that the images appear at those sites. To the extent paragraph
`
`32 purports to include screenshots from https://www.verizon.com/business/solutions/public-
`
`sector/public-safety/first-responder-applications/#video-4
`
`https://www.verizon.com/business/solutions/public-sector/public-safety/first-responder-
`
`applications/#video-8,
`
`and
`
`https://www.verizon.com/business/products/internet-of-
`
`things/connected-smart-cities-communities/real-time-response-system/, Verizon denies
`
`those
`
`screenshots are from these websites. To the extent paragraph 32 purports to include screenshots
`
`
`DM2\16304470.2
`
`8
`
`

`

`Case 2:22-cv-00185-JRG Document 34 Filed 09/14/22 Page 9 of 24 PageID #: 519
`
`from
`
`https://www.youtube.com/watch?v=3T_g6qnwV1Q&t=322s,
`
`https://www.youtube.com/watch?v=-nWcnt91sCM&t=181s,
`
`and
`
`https://www.youtube.com/watch?v=2_p-XWcv-7s&t=7s, Verizon admits that the videos include
`
`those screenshots at the time stamped. To the extent paragraph 32 purports to include excerpts
`
`from
`
`https://www.verizon.com/business/resources/solutionsbriefs/2020/unifying_data_helps_you_mak
`
`e_better_faster_decisions.pdf, Verizon denies there is any excerpt to this document in paragraph
`
`32.
`
`33.
`
`Paragraph 33 sets forth conclusions of law and not averments of facts. To the extent
`
`that any response is necessary, Verizon denies the allegations of paragraph 33.
`
`34.
`
`Paragraph 34 sets forth conclusions of law and not averments of facts. To the extent
`
`that any response is necessary, Verizon denies the allegations of paragraph 34.
`
`35.
`
`Paragraph 35 sets forth conclusions of law and not averments of facts. To the extent
`
`that any response is necessary, Verizon denies the allegations of paragraph 35.
`
`COUNT II (Infringement of the ’838 Patent)
`
`36.
`
`Verizon incorporates by reference paragraphs 1 through 24 as if fully restated
`
`herein.
`
`37.
`
`Verizon is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in paragraph 37, and therefore denies them.
`
`38.
`
`To the extent that the allegations of paragraph 38 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 38 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’838 Patent.
`
`
`DM2\16304470.2
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`9
`
`

`

`Case 2:22-cv-00185-JRG Document 34 Filed 09/14/22 Page 10 of 24 PageID #: 520
`
`39.
`
`To the extent that the allegations of paragraph 39 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 39 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’838 Patent.
`
`40.
`
`To the extent that the allegations of paragraph 40 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 40 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’838 Patent.
`
`41.
`
`To the extent that the allegations of paragraph 41 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 41 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’838 Patent.
`
`42.
`
`To the extent that the allegations of paragraph 42 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 42 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’838 Patent.
`
`43.
`
`To the extent that the allegations of paragraph 43 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 43 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’838 Patent. To the extent paragraph 43 purports to include screenshots from https://reveal-
`
`help.verizonconnect.com/hc/en-us/articles/360010671999-Log-in-to-Reveal,
`
`https://reveal-
`
`help.verizonconnect.com/hc/en-us/articles/360011079099-Reveal-mobile-apps,
`
`https://reveal-
`
`help.verizonconnect.com/hc/en-us/articles/360010589240-Creating-and-editing-groups,
`
`
`DM2\16304470.2
`
`10
`
`

`

`Case 2:22-cv-00185-JRG Document 34 Filed 09/14/22 Page 11 of 24 PageID #: 521
`
`https://reveal-help.verizonconnect.com/hc/en-us/articles/360010567759-Using-the-Live-Map,
`
`https://reveal-help.verizonconnect.com/hc/en-us/articles/360010455560-See-vehicles-on-Live-
`
`Map,
`
`https://reveal-help.verizonconnect.com/hc/en-us/articles/360010567839-Fleet-Status-list,
`
`https://reveal-help.verizonconnect.com/hc/en-us/articles/360010567879-See-your-fleet-status-
`
`on-Live-Map,
`
` https://reveal-help.verizonconnect.com/hc/en-us/articles/360010454660-Find-
`
`nearest-vehicle-or-asset, https://reveal-help.verizonconnect.com/hc/en-us/articles/360010497980-
`
`Creating-Places, and https://reveal-help.verizonconnect.com/hc/en-us/articles/360010567919-
`
`View-job-details, Verizon admits that the images appear at those sites. To the extent paragraph
`
`43 purports to include screenshots from https://www.verizon.com/business/solutions/public-
`
`sector/public-safety/first-responder-applications/#video-2,
`
`https://www.verizon/com/busines/solutions/public-sector/public-safety/first-responder-
`
`applications/#video-3,
`
`https://www.verizon.com/business/solutions/public-sector/public-
`
`safety/first-responder-applications/#video-4, https://www.verizon.com/business/solutions/public-
`
`sector/public-safety/first-responder-applications/#video-8,
`
`and
`
`https://www.verizon.com/business/products/internet-of-things/connected-smart-cities-
`
`communities/real-time-response-system/, Verizon denies those screenshots are from these
`
`websites. To
`
`the
`
`extent paragraph 43 purports
`
`to
`
`include
`
`screenshots
`
`from
`
`https://www.youtube.com/watch?v=mqkL6vCC018,
`
`https://www.youtube.com/watch?v=bvvqpe9fkzs&t=2s,
`
`https://www.youtube.com/watch?v=3T_g6qnwV1Q&t=322s,
`
`https://www.youtube.com/watch?v=-nWcnt91sCM&t=181s,
`
`and
`
`https://www.youtube.com/watch?v=2_p-XWcv-7s&t=7s, Verizon admits that the videos include
`
`those screenshots at the time stamped. To the extent paragraph 43 purports to include excerpts
`
`
`DM2\16304470.2
`
`11
`
`

`

`Case 2:22-cv-00185-JRG Document 34 Filed 09/14/22 Page 12 of 24 PageID #: 522
`
`from
`
`https://www.verizon.com/business/resources/solutionsbriefs/2020/unifying_data_helps_you_mak
`
`e_better_faster_decisions.pdf, Verizon denies there is any excerpt to this document in paragraph
`
`43.
`
`44.
`
`To the extent that the allegations of paragraph 44 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 44. To the extent
`
`paragraph 44 purports to include screenshots from https://www.verizonconnect.com/ and
`
`https://www.verizonconnect.com/resources/video/live-map/, Verizon admits that the images
`
`appear at those sites.
`
`45.
`
`46.
`
`47.
`
`Verizon denies the allegations of paragraph 45.
`
`Verizon denies the allegations of paragraph 46.
`
`Verizon denies the allegations of paragraph 47. To the extent paragraph 47 purports
`
`to include a screenshot from https://www.verizonconnect.com/, Verizon admits that the image
`
`appears at that site.
`
`48.
`
`Verizon denies the allegations of paragraph 48. To the extent paragraph 48 purports
`
`to include a screenshot from https://www.verizonconnect.com/, Verizon admits that the image
`
`appears at that site.
`
`49.
`
`50.
`
`Verizon denies the allegations of paragraph 49.
`
`Paragraph 50 sets forth conclusions of law and not averments of facts. To the extent
`
`that any response is necessary, Verizon denies the allegations of paragraph 50.
`
`51.
`
`Paragraph 51 sets forth conclusions of law and not averments of facts. To the extent
`
`that any response is necessary, Verizon denies the allegations of paragraph 51.
`
`
`DM2\16304470.2
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`12
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`

`

`Case 2:22-cv-00185-JRG Document 34 Filed 09/14/22 Page 13 of 24 PageID #: 523
`
`52.
`
`Paragraph 52 sets forth conclusions of law and not averments of facts. To the extent
`
`that any response is necessary, Verizon denies the allegations of paragraph 52.
`
`COUNT III (Infringement of the ’829 Patent)
`
`53.
`
`Verizon incorporates by reference paragraphs 1 through 24 as if fully restated
`
`herein.
`
`54.
`
`Verizon is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in paragraph 54, and therefore denies them.
`
`55.
`
`To the extent that the allegations of paragraph 55 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 55 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’829 Patent.
`
`56.
`
`To the extent that the allegations of paragraph 56 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 56 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’829 Patent.
`
`57.
`
`To the extent that the allegations of paragraph 57 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 57 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’829 Patent.
`
`58.
`
`To the extent that the allegations of paragraph 58 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 58 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’829 Patent.
`
`
`DM2\16304470.2
`
`13
`
`

`

`Case 2:22-cv-00185-JRG Document 34 Filed 09/14/22 Page 14 of 24 PageID #: 524
`
`59.
`
`To the extent that the allegations of paragraph 59 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 59 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’829 Patent. To the extent paragraph 59 purports to include screenshots from https://reveal-
`
`help.verizonconnect.com/hc/en-us/articles/360010671999-Log-in-to-Reveal,
`
`https://reveal-
`
`help.verizonconnect.com/hc/en-us/articles/360011079099-Reveal-mobile-apps,
`
`https://reveal-
`
`help.verizonconnect.com/hc/en-us/articles/360010589240-Creating-and-editing-groups,
`
`https://reveal-help.verizonconnect.com/hc/en-us/articles/360010567759-Using-the-Live-Map,
`
`https://reveal-help.verizonconnect.com/hc/en-us/articles/360010455560-See-vehicles-on-Live-
`
`Map,
`
`https://reveal-help.verizonconnect.com/hc/en-us/articles/360010567839-Fleet-Status-list,
`
`https://reveal-help.verizonconnect.com/hc/en-us/articles/360010567879-See-your-fleet-status-
`
`on-Live-Map,
`
` https://reveal-help.verizonconnect.com/hc/en-us/articles/360010454660-Find-
`
`nearest-vehicle-or-asset, https://reveal-help.verizonconnect.com/hc/en-us/articles/360010497980-
`
`Creating-Places, and https://reveal-help.verizonconnect.com/hc/en-us/articles/360010567919-
`
`View-job-details, Verizon admits that the images appear at those sites. To the extent paragraph
`
`59 purports to include screenshots from https://www.verizon.com/business/solutions/public-
`
`sector/public-safety/first-responder-applications/#video-2,
`
`https://www.verizon/com/busines/solutions/public-sector/public-safety/first-responder-
`
`applications/#video-3,
`
`https://www.verizon.com/business/solutions/public-sector/public-
`
`safety/first-responder-applications/#video-4, https://www.verizon.com/business/solutions/public-
`
`sector/public-safety/first-responder-applications/#video-8,
`
`and
`
`https://www.verizon.com/business/products/internet-of-things/connected-smart-cities-
`
`communities/real-time-response-system/, Verizon denies those screenshots are from these
`
`
`DM2\16304470.2
`
`14
`
`

`

`Case 2:22-cv-00185-JRG Document 34 Filed 09/14/22 Page 15 of 24 PageID #: 525
`
`websites. To
`
`the
`
`extent paragraph 59 purports
`
`to
`
`include
`
`screenshots
`
`from
`
`https://www.youtube.com/watch?v=mqkL6vCC018,
`
`https://www.youtube.com/watch?v=bvvqpe9fkzs&t=2s,
`
`https://www.youtube.com/watch?v=3T_g6qnwV1Q&t=322s,
`
`https://www.youtube.com/watch?v=-nWcnt91sCM&t=181s,
`
`and
`
`https://www.youtube.com/watch?v=2_p-XWcv-7s&t=7s, Verizon admits that the videos include
`
`those screenshots at the time stamped. To the extent paragraph 59 purports to include excerpts
`
`from
`
`https://www.verizon.com/business/resources/solutionsbriefs/2020/unifying_data_helps_you_mak
`
`e_better_faster_decisions.pdf, Verizon denies there is any excerpt to this document in paragraph
`
`59.
`
`60.
`
`To the extent that the allegations of paragraph 60 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 60. To the extent
`
`paragraph 60 purports to include screenshots from https://www.verizonconnect.com/ and
`
`https://www.verizonconnect.com/resources/video/live-map/, Verizon admits that the images
`
`appear at those sites.
`
`61.
`
`62.
`
`Verizon denies the allegations of paragraph 61.
`
`Verizon denies the allegations of paragraph 62. To the extent paragraph 62 purports
`
`to
`
`include
`
`a
`
`screenshot
`
`from
`
`https://reveal-help.verizonconnect.com/hc/en-
`
`us/articles/360010567919-View-job-details, Verizon admits that the image appears at that site.
`
`63.
`
`Verizon denies the allegations of paragraph 63. To the extent paragraph 63 purports
`
`to
`
`include
`
`a
`
`screenshot
`
`from
`
`https://reveal-help.verizonconnect.com/hc/en-
`
`
`DM2\16304470.2
`
`15
`
`

`

`Case 2:22-cv-00185-JRG Document 34 Filed 09/14/22 Page 16 of 24 PageID #: 526
`
`us/articles/360010589240-Creating-and-editing-groups, Verizon admits that the image appears at
`
`that site.
`
`64.
`
`Verizon denies the allegations of paragraph 64. To the extent paragraph 64 purports
`
`to
`
`include
`
`screenshots
`
`from
`
`https://www.verizonconnect.com/
`
`and
`
`https://www.verizonconnect.com/resources/video/live-map/, Verizon admits that the images
`
`appear at those sites.
`
`65.
`
`66.
`
`Verizon denies the allegations of paragraph 65.
`
`Paragraph 66 sets forth conclusions of law and not averments of facts. To the extent
`
`that any response is necessary, Verizon denies the allegations of paragraph 66.
`
`67.
`
`Paragraph 67 sets forth conclusions of law and not averments of facts. To the extent
`
`that any response is necessary, Verizon denies the allegations of paragraph 67.
`
`68.
`
`Paragraph 68 sets forth conclusions of law and not averments of facts. To the extent
`
`that any response is necessary, Verizon denies the allegations of paragraph 68.
`
`COUNT IV (Infringement of the ’123 Patent)
`
`69.
`
`Verizon incorporates by reference paragraphs 1 through 24 as if fully restated
`
`herein.
`
`70.
`
`Verizon is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in paragraph 70, and therefore denies them.
`
`71.
`
`To the extent that the allegations of paragraph 71 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 71 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’123 Patent.
`
`72.
`
`To the extent that the allegations of paragraph 72 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 72 including
`
`
`DM2\16304470.2
`
`16
`
`

`

`Case 2:22-cv-00185-JRG Document 34 Filed 09/14/22 Page 17 of 24 PageID #: 527
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’123 Patent.
`
`73.
`
`To the extent that the allegations of paragraph 73 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 73 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’123 Patent.
`
`74.
`
`To the extent that the allegations of paragraph 74 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 74 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’123 Patent.
`
`75.
`
`To the extent that the allegations of paragraph 75 set forth legal conclusions, no
`
`response is required. Verizon denies any remaining allegations of paragraph 75 including
`
`specifically that any of the Verizon Defendants infringe, in any fashion, any valid claim of the
`
`’123 Patent. To the extent paragraph 75 purports to include screenshots from https://reveal-
`
`help.verizonconnect.com/hc/en-us/articles/360010671999-Log-in-to-Reveal,
`
`https://reveal-
`
`help.verizonconnect.com/hc/en-us/articles/360011079099-Reveal-mobile-apps,
`
`https://reveal-
`
`help.verizonconnect.com/hc/en-us/articles/360010589240-Creating-and-editing-groups,
`
`https://reveal-help.verizonconnect.com/hc/en-us/articles/360010567759-Using-the-Live-Map,
`
`https://reveal-help.verizonconnect.com/hc/en-us/articles/360010455560-See-vehicles-on-Live-
`
`Map,
`
`https://reveal-help.verizonconnect.com/hc/en-us/articles/360010567839-Fleet-Status-list,
`
`https://reveal-help.verizonconnect.com/hc/en-us/articles/360010567879-See-your-fleet-status-
`
`on-Live-Map,
`
` https://reveal-help.verizonconnect.com/hc/en-us/articles/360010454660-Find-
`
`nearest-vehicle-or-asset, https://reveal-help.verizonconnect.com/hc/en-us/articles/360010497980-
`
`
`DM2\16304470.2
`
`17
`
`

`

`Case 2:22-cv-00185-JRG Document 34 Filed 09/14/22 Page 18 of 24 PageID #: 528
`
`Creating-Places, and https://reveal-help.verizonconnect.com/hc/en-us/articles/360010567919-
`
`View-job-details, Verizon admits that the images appear at those sites. To the extent paragraph
`
`75 purports to include screenshots from https://www.verizon.com/business/solutions/public-
`
`sector/public-safety/first-responder-applications/#video-2,
`
`https://www.verizon/com/busines/solution