Case 2:22-cv-00443-JRG Document 44 Filed 01/16/24 Page 1 of 14 PageID #: 932
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`
`Plaintiff
`
`
`v.
`
`HMD GLOBAL OY and
`HMD AMERICA, INC.
`
`
`Defendants.
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`Case No. 2:22-cv-00443-JRG
`(Lead Case)
`
`
`DEFENDANT HMD GLOBAL OY’S ANSWER TO AGIS SOFTWARE
`DEVELOPMENT LLC’S COMPLAINT FOR PATENT INFRINGEMENT
`
`Defendant HMD Global Oy (“HMD”) hereby answers the Complaint of Plaintiff AGIS
`
`Software Development LLC (“AGIS”). To the extent not explicitly admitted, all allegations of the
`
`complaint are denied.
`
`PARTIES
`
`1.
`
`HMD lacks sufficient knowledge or information to either admit or deny the
`
`allegations in paragraph 1 of the Complaint, and therefore denies them.
`
`2.
`
`3.
`
`Denied.
`
`HMD admits that HMD Global Oy is a corporation organized and existing under
`
`the laws of Finland, with its principal place of business at Bertel Jungin aukio 9, 02600 Espoo,
`
`Finland. HMD denies the remaining allegations in this paragraph.
`
`4.
`
`HMD admits that HMD America, Inc. (“HMD America”) is a corporation
`
`organized and existing under the laws of the State of Florida, with its principal place of business
`
`at 1200 Brickell Ave., Suite. 510, Miami, Florida 33131. HMD admits that HMD America is
`
`
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`
`Plaintiff
`
`
`v.
`
`HMD GLOBAL OY and
`HMD AMERICA, INC.
`
`
`Defendants.
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`Case No. 2:22-cv-00443-JRG
`(Lead Case)
`
`
`DEFENDANT HMD GLOBAL OY’S ANSWER TO AGIS SOFTWARE
`DEVELOPMENT LLC’S COMPLAINT FOR PATENT INFRINGEMENT
`
`Defendant HMD Global Oy (“HMD”) hereby answers the Complaint of Plaintiff AGIS
`
`Software Development LLC (“AGIS”). To the extent not explicitly admitted, all allegations of the
`
`complaint are denied.
`
`PARTIES
`
`1.
`
`HMD lacks sufficient knowledge or information to either admit or deny the
`
`allegations in paragraph 1 of the Complaint, and therefore denies them.
`
`2.
`
`3.
`
`Denied.
`
`HMD admits that HMD Global Oy is a corporation organized and existing under
`
`the laws of Finland, with its principal place of business at Bertel Jungin aukio 9, 02600 Espoo,
`
`Finland. HMD denies the remaining allegations in this paragraph.
`
`4.
`
`HMD admits that HMD America, Inc. (“HMD America”) is a corporation
`
`organized and existing under the laws of the State of Florida, with its principal place of business
`
`at 1200 Brickell Ave., Suite. 510, Miami, Florida 33131. HMD admits that HMD America is
`
`
`
`
`
`Case 2:22-cv-00443-JRG Document 44 Filed 01/16/24 Page 2 of 14 PageID #: 933
`
`registered to transact business in Texas and may be served with process through its registered
`
`agent. HMD denies the remaining allegations in this paragraph.
`
`5.
`
`HMD lacks sufficient knowledge or information to either admit or deny the
`
`allegations in paragraph 5 of the Complaint, and therefore denies them.
`
`JURISDICTION AND VENUE
`
`6.
`
`HMD admits that the Complaint purports to initiate an action for patent
`
`infringement under the patent laws of the United States of America, contained in Title 35 of the
`
`United States Code. HMD admits that this Court has jurisdiction under 28. U.S.C. §§ 1331 and
`
`1338(a) over claims for patent infringement but denies it has committed any act that would give
`
`rise to any cause of action in the Complaint. Otherwise, denied.
`
`7.
`
`8.
`
`Denied.
`
`HMD admits that HMD Global Oy is a foreign corporation formed under the laws
`
`of Finland with a principal place of business in Finland. Otherwise, denied.
`
`PATENTS-IN-SUIT
`
`9.
`
`HMD admits that the face of the ’970 patent indicates that it issued on July 3,
`
`2012, and that it is entitled “Method of Utilizing Forced Alerts for Interactive Remote
`
`Communications.” HMD lacks sufficient knowledge or information to either admit or deny the
`
`remaining allegations in this paragraph of the Complaint, and therefore denies them.
`
`10.
`
`HMD admits that the face of the ’251 patent indicates that it issued on September
`
`13, 2016, and that it is entitled “Method to Provide Ad Hoc and Password Protected Digital and
`
`Voice Networks.” HMD lacks sufficient knowledge or information to either admit or deny the
`
`remaining allegations in this paragraph of the Complaint, and therefore denies them.
`
`11.
`
`HMD admits that the face of the ’838 patent indicates that it issued on October
`
`11, 2016, and that it is entitled “Method to Provide Ad Hoc and Password Protected Digital and
`
`2
`
`
`
`Case 2:22-cv-00443-JRG Document 44 Filed 01/16/24 Page 3 of 14 PageID #: 934
`
`Voice Networks.” HMD lacks sufficient knowledge or information to either admit or deny the
`
`remaining allegations in this paragraph of the Complaint, and therefore denies them.
`
`12.
`
`HMD admits that the face of the ’829 patent indicates that it issued on August 29,
`
`2017, and that it is entitled “Method to Provide Ad Hoc and Password Protected Digital and
`
`Voice Networks.” HMD lacks sufficient knowledge or information to either admit or deny the
`
`remaining allegations in this paragraph of the Complaint, and therefore denies them.
`
`13.
`
`HMD admits that the face of the ’123 patent indicates that it issued on November
`
`14, 2017, and that it is entitled “Method to Provide Ad Hoc and Password Protected Digital and
`
`Voice Networks.” HMD lacks sufficient knowledge or information to either admit or deny the
`
`remaining allegations in this paragraph of the Complaint, and therefore denies them.
`
`14.
`
`HMD lacks sufficient knowledge or information to either admit or deny the
`
`allegations in paragraph 14 of the Complaint, and therefore denies them.
`
`FACTUAL ALLEGATIONS
`
`15.
`
`HMD lacks sufficient knowledge or information to either admit or deny the
`
`allegations in paragraph 15 of the Complaint, and therefore denies them.
`
`16.
`
`HMD lacks sufficient knowledge or information to either admit or deny the
`
`allegations in paragraph 16 of the Complaint, and therefore denies them.
`
`17.
`
`HMD lacks sufficient knowledge or information to either admit or deny the
`
`allegations in paragraph 17 of the Complaint, and therefore denies them.
`
`18.
`
`19.
`
`Denied.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`3
`
`
`
`Case 2:22-cv-00443-JRG Document 44 Filed 01/16/24 Page 4 of 14 PageID #: 935
`
`COUNT 1 - INFRINGEMENT OF THE ’970 PATENT
`
`20.
`
`HMD repeats and incorporates by reference, as if fully set forth herein, its
`
`answers to paragraphs 1-19, as set forth above.
`
`21.
`
`HMD lacks sufficient knowledge or information to either admit or deny the
`
`allegations in paragraph 21 of the Complaint, and therefore denies them.
`
`22.
`
`23.
`
`24.
`
`25.
`
`26.
`
`27.
`
`28.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`COUNT 2 - INFRINGEMENT OF THE ’251 PATENT
`
`29.
`
`HMD repeats and incorporates by reference, as if fully set forth herein, its
`
`answers to paragraphs 1-19, as set forth above.
`
`30.
`
`HMD lacks sufficient knowledge or information to either admit or deny the
`
`allegations in paragraph 30 of the Complaint, and therefore denies them.
`
`31.
`
`32.
`
`33.
`
`34.
`
`35.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`4
`
`
`
`Case 2:22-cv-00443-JRG Document 44 Filed 01/16/24 Page 5 of 14 PageID #: 936
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`36.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`37.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`38.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`39.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`40.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`41.
`
`42.
`
`Denied.
`
`Denied.
`
`COUNT 3 - INFRINGEMENT OF THE ’838 PATENT
`
`43.
`
`HMD repeats and incorporates by reference, as if fully set forth herein, its
`
`answers to paragraphs 1-19, as set forth above.
`
`44.
`
`HMD lacks sufficient knowledge or information to either admit or deny the
`
`allegations in paragraph 44 of the Complaint, and therefore denies them.
`
`5
`
`
`
`Case 2:22-cv-00443-JRG Document 44 Filed 01/16/24 Page 6 of 14 PageID #: 937
`
`45.
`
`46.
`
`47.
`
`48.
`
`49.
`
`Denied.
`
`Denied.
`
`Denied.
`
`Denied.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`50.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`51.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`52.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`53.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`54.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`55.
`
`Denied.
`
`6
`
`
`
`Case 2:22-cv-00443-JRG Document 44 Filed 01/16/24 Page 7 of 14 PageID #: 938
`
`56.
`
`Denied.
`
`COUNT 4 - INFRINGEMENT OF THE ’829 PATENT
`
`57.
`
`HMD repeats and incorporates by reference, as if fully set forth herein, its
`
`answers to paragraphs 1-19, as set forth above.
`
`58.
`
`HMD lacks sufficient knowledge or information to either admit or deny the
`
`allegations in paragraph 58 of the Complaint, and therefore denies them.
`
`59.
`
`60.
`
`61.
`
`62.
`
`Denied.
`
`Denied.
`
`Denied.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`63.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`64.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`65.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`66.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`7
`
`
`
`Case 2:22-cv-00443-JRG Document 44 Filed 01/16/24 Page 8 of 14 PageID #: 939
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`67.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`68.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`69.
`
`70.
`
`Denied.
`
`Denied.
`
`COUNT 5 - INFRINGEMENT OF THE ’123 PATENT
`
`71.
`
`HMD repeats and incorporates by reference, as if fully set forth herein, its
`
`answers to paragraphs 1-19, as set forth above.
`
`72.
`
`HMD lacks sufficient knowledge or information to either admit or deny the
`
`allegations in paragraph 72 of the Complaint, and therefore denies them.
`
`73.
`
`74.
`
`75.
`
`76.
`
`Denied.
`
`Denied.
`
`Denied.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`77.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`8
`
`
`
`Case 2:22-cv-00443-JRG Document 44 Filed 01/16/24 Page 9 of 14 PageID #: 940
`
`78.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`79.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`80.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`81.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`82.
`
`This paragraph states legal conclusions that require no response, at least because
`
`the Court has yet to construe the claim terms that appear in this paragraph. To the extent the
`
`Court requires a response, HMD denies the allegations of this paragraph.
`
`83.
`
`84.
`
`Denied.
`
`Denied.
`
`DEMAND FOR JURY TRIAL
`
`No response is required to AGIS’s demand for trial by jury. HMD separately requests a
`
`jury trial on each of its defenses.
`
`PRAYER FOR RELIEF
`
`HMD denies AGIS is entitled to any of the relief it requests.
`
`9
`
`
`
`Case 2:22-cv-00443-JRG Document 44 Filed 01/16/24 Page 10 of 14 PageID #: 941
`
`HMD’S DEFENSES
`
`HMD incorporates by reference the foregoing paragraphs in their entirety and asserts the
`
`following defenses in response to the allegations, included defenses set forth at 35 U.S.C. §282,
`
`undertaking the burden of proof only as to those defenses deemed affirmative defenses by law,
`
`regardless of how such defenses are denominated herein. In addition to the defenses described
`
`below, subject to its responses above, HMD specifically reserves all rights to allege additional
`
`defenses that become known through the course of discovery.
`
`FIRST DEFENSE
`(No Infringement)
`
`Based on a reasonable investigation into inter alia the allegations in the complaint, HMD
`
`does not infringe and has not infringed—directly, indirectly, literally, or under the doctrine of
`
`equivalents—any valid and enforceable claim of U.S. Patent Nos. 8,213,970, 9,445,251,
`
`9,467,838, 9,749,829, and 9,820,123 (the “Asserted Patents” and each an “Asserted Patent”).
`
`SECOND DEFENSE
`(Invalidity)
`
`Based on a reasonable investigation into inter alia public filings, each asserted claim of
`
`the Asserted Patents is invalid for failure to comply with one or more requirements of the patent
`
`laws of the United States, including but not limited to 35 U.S.C. §§ 101 et seq., e.g., 102, 103,
`
`and/or 112, and/or for otherwise being in violation of the sections of Parts I, II, and III of Title 35
`
`of the United States Code.
`
`THIRD DEFENSE
`(Prosecution History Estoppel)
`
`By reason of the statements, representations, admissions, concessions, arguments, and/or
`
`amendments made by and/or on behalf of the applicants to and by the U.S. Patent and Trademark
`
`Office (“PTO”) during the prosecution of the patent applications that led to the issuance of the
`
`10
`
`
`
`Case 2:22-cv-00443-JRG Document 44 Filed 01/16/24 Page 11 of 14 PageID #: 942
`
`Asserted Patents, AGIS’s claims of patent infringement are barred, in whole or in part, by the
`
`doctrine of prosecution history estoppel and/or disclaimer. Evidence supporting this defense was
`
`previously identified to AGIS in ITC Investigation No. 337-TA-1347 against HMD and others
`
`(Certain Location-Sharing Systems, Related Software, Components Thereof, and Products
`
`Containing Same) regarding the September 9, 2011 amendments to the claims of the ’970 Patent.
`
`Defendants are investigating the facts relating to the procurement of the Asserted Patents and the
`
`assertion of infringement against them and will continue to do so. To the extent that this
`
`investigation reveals any improprieties in connection with such matters, Defendants reserve the
`
`right to seek leave to amend to assert such allegations and/or defenses based thereon that may be
`
`appropriate.
`
`FOURTH DEFENSE
`(Improper Venue)
`
`Venue is neither proper nor convenient for HMD America in the Eastern District of Texas,
`
`and is not convenient for HMD Global.
`
`FIFTH DEFENSE
`(License and/or Exhaustion)
`
`AGIS’s claims for patent infringement are barred in whole or in part (i) to the extent that
`
`any allegedly infringing products or services are supplied, directly or indirectly, to HMD by any
`
`entities having express or implied licenses to the Asserted Patents, or by HMD to any entities
`
`having express or implied licenses to the Asserted Patents, and/or (iii) under the doctrine of
`
`patent exhaustion.
`
`SIXTH DEFENSE
`(Limitations on Damages and Costs)
`
`AGIS’s claims for damages for alleged infringement are limited by 35 U.S.C. §§ 286
`
`and/or 287 and/or the doctrine of intervening rights, at least because AGIS failed to provide
`
`11
`
`
`
`Case 2:22-cv-00443-JRG Document 44 Filed 01/16/24 Page 12 of 14 PageID #: 943
`
`adequate notice to Defendants of alleged infringement and are thus barred under 35 U.S.C. § 287
`
`from recovering damages on one or more claims on dates prior to the date of the filing of this
`
`action. AGIS is further barred by 35 U.S.C. § 288 from recovering any costs associated with this
`
`action. In addition, AGIS is precluded from recovering damages for any alleged infringement
`
`occurring more than six years prior to the filing of this action pursuant to 35 U.S.C. § 286.
`
`SEVENTH DEFENSE
`(Equitable Defenses)
`
`AGIS’s claims are barred in whole or in part under principles of equity, including but not
`
`limited to prosecution laches, delay, waiver, implied waiver, acquiescence, estoppel, and/or
`
`unclean hands.
`
`EIGHTH DEFENSE
`(AGIS Cannot Prove Exceptional Case)
`
`AGIS cannot prove that this is an exceptional case justifying an award of attorney’s fees
`
`pursuant to 35 U.S.C. § 285.
`
`NINTH DEFENSE
`(Lack of Standing)
`
`Under the standing defense identified in AGIS Software Development LLC v. T-Mobile
`
`USA, Inc. et al., 2:21-cv-00072-JRG at Docket Nos. 25 and 52, AGIS lacks standing to pursue at
`
`least some of its claims of infringement.
`
`RESERVATION OF RIGHTS
`
`HMD reserves all defenses under Rule 8(c) of the Federal Rules of Civil Procedure, the
`
`Patent Laws of the United States and any other defenses, at law or in equity, which may now
`
`exist or in the future be available based on discovery, including all those identified in the
`
`answers of the other defendants in these joined cases. HMD reserves its rights to amend should
`
`it learn of additional defenses.
`
`12
`
`
`
`Case 2:22-cv-00443-JRG Document 44 Filed 01/16/24 Page 13 of 14 PageID #: 944
`
`
`
`Dated: January 16, 2024
`
`
`
`
`Respectfully submitted,
`
`/s/ Matthew J. Moffa
`
`MATTHEW J. MOFFA
`(Admitted E.D. Tex.)
`MMoffa@perkinscoie.com
`Perkins Coie LLP
`1155 Avenue of the Americas, 22nd Floor
`New York, NY 10036-2711
`Telephone: (212) 261-6857
`Facsimile: (737) 256-6300
`
`DAKOTA P. KANETZKY
`Texas Bar No. 24116599
`DKanetzky@perkinscoie.com
`PERKINS COIE LLP
`405 Colorado Street, Suite 1700
`Austin, Texas 78701
`Telephone: (737) 256-6115
`Facsimile: (737) 256-6300
`
`Attorneys for Defendants HMD America, Inc.
`and HMD Global Oy
`
`13
`
`
`
`Case 2:22-cv-00443-JRG Document 44 Filed 01/16/24 Page 14 of 14 PageID #: 945
`
`CERTIFICATE OF SERVICE
`The undersigned certifies that on January 16, 2024, a true and correct copy of the above
`
`document was served on all counsel of record who are deemed to have consented to electronic
`
`service via the Court’s CM/ECF system per Local Rule CV-5(a)(3)(A).
`
`
`
`/s/ Matthew J. Moffa
`Matthew J. Moffa
`
`
`
`14
`
`
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