Case 2:24-cv-00162-JRG-RSP Document 12 Filed 05/03/24 Page 1 of 33 PageID #:
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`BTYEWEAVR, LLC,
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`Plaintiff,
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`v.
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`
`
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`DATABRICKS, INC.,
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`Civil Action No. 2:24-cv-00162-JRG-RSP
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` JURY TRIAL DEMANDED
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`Defendant.
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`ANSWER OF DEFENDANT DATABRICKS, INC.
`TO COMPLAINT FOR PATENT INFRINGEMENT
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`Defendant Databricks, Inc. (“Databricks”) hereby files its Answer and Affirmative
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`Defenses to the complaint of Plaintiff Byteweavr, LLC (“Byteweavr”). Each of the paragraphs
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`below corresponds to the same numbered paragraph in the complaint. In responding to the
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`complaint, Databricks has included several of Plaintiff’s headings for ease of reference, but in
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`doing so, Databricks is not admitting to the accuracy of any statements made or agreeing with any
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`characterizations made in such headings. Headings are used solely for organization and do not in
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`any case act as an admission or statement. Databricks denies all allegations in the complaint,
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`whether express or implied, that are not specifically admitted below. Databricks further denies
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`that Byteweavr is entitled to the relief requested in the complaint, or to any other relief.
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`THE PARTIES
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`1.
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`Databricks lacks sufficient information to form a belief as to the truth or falsity of
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`the allegations of paragraph 1 of the complaint and, on that basis, denies them.
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`2.
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`Databricks admits that it is a corporation organized under the laws of the state of
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`Delaware, with a principal place of business of 160 Spear Street, San Francisco, CA 94105, but
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`1
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`Databricks denies that its principal place of business is in Suite 1300. Databricks further admits
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`that it is registered to do business in Texas, and that its registered agent is United Agent Group
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`Inc. Except as expressly admitted, Databricks denies the remaining allegations in paragraph 2.
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`3.
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`Databricks admits that it was founded in 2013. To the extent the allegations in
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`paragraph 3 purport to quote or characterize the contents of Databricks webpages, each document
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`speaks for itself. To the extent the Complaint incorrectly or incompletely quotes or characterizes
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`the cited webpages, Databricks denies the allegations in Paragraph 3. Databricks lacks knowledge
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`or information sufficient to admit or deny the remaining allegations of paragraph 3 of the
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`complaint, and on that basis, denies them.
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`4.
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`To the extent the allegations in paragraph 4 purport to quote or characterize the
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`contents of Databricks webpages, each document speaks for itself. To the extent the Complaint
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`incorrectly or incompletely quotes or characterizes the cited webpages, Databricks denies the
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`allegations in Paragraph 4. Except as expressly admitted, Databricks denies the remaining
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`allegations in paragraph 4.
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`5.
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`To the extent the allegations in paragraph 5 purport to quote or characterize the
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`contents of Databricks webpages, each document speaks for itself. To the extent the Complaint
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`incorrectly or incompletely quotes or characterizes the cited webpages, Databricks denies the
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`allegations in Paragraph 5. Databricks admits it published a blog entitled “What is a Lakehouse”
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`in 2020, in which “Lakehouse” was announced to the public. Except as expressly admitted,
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`Databricks denies the remaining allegations in paragraph 5.
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`6.
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`To the extent the allegations in paragraph 6 purport to quote or characterize the
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`contents of Databricks webpages, each document speaks for itself. To the extent the Complaint
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`incorrectly or incompletely quotes or characterizes the cited webpages, Databricks denies the
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`2
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`allegations in Paragraph 6. Except as expressly admitted, Databricks denies the remaining
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`allegations in paragraph 6.
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`7.
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`To the extent the allegations in paragraph 7 purport to quote or characterize the
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`contents of Databricks webpages, each document speaks for itself. To the extent the Complaint
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`incorrectly or incompletely quotes or characterizes the cited webpages, Databricks denies the
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`allegations in Paragraph 7. Except as expressly admitted, Databricks denies the remaining
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`allegations in paragraph 7.
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`8.
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`Databricks admits it maintains a corporate and commercial presence in the United
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`States. To the extent the allegations in paragraph 8 purport to quote or characterize the contents
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`of a Databricks webpage, the document speaks for itself. To the extent the Complaint incorrectly
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`or incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
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`Paragraph 8. Except as expressly admitted, Databricks denies the remaining allegations in
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`paragraph 8.
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`ALLEGED JURISDICTION AND VENUE
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`9.
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`The allegations in this paragraph state a legal conclusion to which no response is
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`required. To the extent a response is deemed required, Databricks admits that the complaint
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`purports to allege that this civil action arises under the Patent Laws of the United States, 35 U.S.C.
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`§§ 271, 281, and 284-285, but denies that the allegations have any merit or that Plaintiff is entitled
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`to any relief.
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`10.
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`Databricks admits that this Court has subject matter jurisdiction over infringement
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`claims brought by the owner or exclusive licensee of a patent pursuant to 28 U.S.C. §§ 1331 and
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`1338(a), but Databricks lack knowledge and information sufficient to form a belief as to whether
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`Plaintiff is the owner or exclusive licensee of the patents in suit.
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`3
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`11.
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`The allegations in this paragraph state a legal conclusion to which no response is
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`required. To the extent a response is deemed to be required, Databricks admits that this Court has
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`personal jurisdiction over Databricks with respect to the instant action. Databricks denies that it
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`has committed or is committing any acts of infringement anywhere, including in this District.
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`Except as expressly admitted, Databricks denies the remaining allegations in paragraph 11.
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`12.
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`To the extent the allegations in paragraph 12 purport to quote or characterize the
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`contents of a Databricks webpage, the document speaks for itself. To the extent the Complaint
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`incorrectly or incompletely quotes or characterizes the cited webpage, Databricks denies the
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`allegations in Paragraph 12. Except as expressly admitted, Databricks denies the remaining
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`allegations in paragraph 12.
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`13.
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`Databricks denies the allegations of paragraph 13 of the complaint. Databricks
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`specifically denies that it has committed any acts of infringement.
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`14.
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`The allegations in this paragraph state a legal conclusion to which no response is
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`required. To the extent a response is deemed to be required, Databricks admits that this Court has
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`personal jurisdiction over Databricks with respect to the instant action. Databricks denies that it
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`has committed or is committing any acts of infringement anywhere, including in this District. To
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`the extent the allegations in paragraph 14 purport to quote or characterize the contents of a
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`Databricks webpage, the document speaks for itself. To the extent the Complaint incorrectly or
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`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
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`Paragraph 14. Databricks denies the remaining allegations in paragraph 14, and specifically denies
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`that it has committed any acts of infringement.
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`15.
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`To the extent the allegations in paragraph 15 purport to quote or characterize the
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`contents of Databricks webpages and/or a Federal Circuit Court case law, or an Eastern District of
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`4
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`Texas case law, the document speaks for itself. To the extent the Complaint incorrectly or
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`incompletely quotes or characterizes the cited documents, Databricks denies the allegations in
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`Paragraph 15. The allegations in this paragraph state a legal conclusion to which no response is
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`required. Databricks denies the remaining allegations in paragraph 15, and specifically denies that
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`it has committed any acts of infringement.
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`16.
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`The allegations in this paragraph state a legal conclusion to which no response is
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`required. To the extent a response is deemed to be required, Databricks does not dispute, for this
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`action only, that venue is authorized in this District pursuant to 28 U.S.C. § 1400(b) and that this
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`Court has personal jurisdiction over it with respect to the instant action. By filing this answer,
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`Databricks does not waive any argument that venue is inconvenient in this District, or that this
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`action should be transferred to another district for the convenience of the parties and witnesses and
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`in the interest of justice. Databricks denies the remaining allegations in paragraph 16, and
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`specifically denies that it has committed any acts of infringement.
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`17.
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`The allegations in this paragraph state a legal conclusion to which no response is
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`required. To the extent a response is deemed to be required, Databricks does not dispute, for this
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`action only, that venue is authorized in this District pursuant to 28 U.S.C. § 1400(b) and that this
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`Court has personal jurisdiction over it with respect to the instant action. Databricks specifically
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`denies that venue is convenient in this District and reserves all right to contend that this action
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`should be transferred to another district for the convenience of the parties and witnesses and in the
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`interest of justice. Except as expressly admitted, Databricks denies the remaining allegations in
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`paragraph 17.
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`5
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`THE ASSERTED PATENT AND TECHNOLOGY
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`18.
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`To the extent Paragraph 18 states a legal conclusion, no response is required.
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`Databricks lacks knowledge or information sufficient to admit or deny the allegations of paragraph
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`18 of the complaint and, on that basis, denies them.
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`19.
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`Databricks lacks knowledge or information sufficient to admit or deny the
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`allegations of paragraph 19 of the complaint and, on that basis, denies them.
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`20.
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`Databricks lacks knowledge or information sufficient to admit or deny the
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`allegations of paragraph 20 of the complaint and, on that basis, denies them.
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`21.
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`Databricks lacks knowledge or information sufficient to admit or deny the
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`allegations of paragraph 21 of the complaint and, on that basis, denies them.
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`22.
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`Databricks lacks knowledge or information sufficient to admit or deny the
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`allegations of paragraph 22 of the complaint and, on that basis, denies them.
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`23.
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`Databricks lacks knowledge or information sufficient to admit or deny the
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`allegations of paragraph 23 of the complaint and, on that basis, denies them.
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`24.
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`Databricks lacks knowledge or information sufficient to admit or deny the
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`allegations of paragraph 24 of the complaint and, on that basis, denies them.
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`25.
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`Databricks lacks knowledge or information sufficient to admit or deny the
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`allegations of paragraph 25 of the complaint and, on that basis, denies them.
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`26.
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`To the extent the allegations in paragraph 26 purport to quote or characterize the
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`contents of a Databricks webpage, the document speaks for itself. To the extent the Complaint
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`incorrectly or incompletely quotes or characterizes the cited webpage, Databricks denies the
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`allegations in Paragraph 26. Except as expressly admitted, Databricks denies the remaining
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`allegations in paragraph 26.
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`6
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`27.
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`To the extent Paragraph 27 states a legal conclusion, no response is required. To
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`the extent the allegations in paragraph 27 purport to quote or characterize the contents of a
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`Databricks webpage, the document speaks for itself. To the extent the Complaint incorrectly or
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`incompletely quotes or characterizes the cited webpages, Databricks denies the allegations in
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`Paragraph 27. Databricks admits that it designed and developed the Databricks Lakehouse
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`Platform. Databricks denies the remaining allegations in paragraph 27, and specifically denies
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`that it has committed any acts of infringement.
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`28.
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` To the extent Paragraph 28 states a legal conclusion, no response is required.
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`Paragraph 28 purports to quote and/or characterize the contents of Databricks webpages, each of
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`which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes or
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`characterizes the cited webpages, Databricks denies the allegations in Paragraph 28. Databricks
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`denies the remaining allegations in paragraph 28, and specifically denies that it has committed any
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`acts of infringement.
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`29.
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`Paragraph 29 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 29.
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`30.
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`Paragraph 30 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 30.
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`31.
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`Paragraph 31 purports to quote and/or characterize the contents of Databricks
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`webpages, each of which speaks for itself. To the extent the Complaint incorrectly or incompletely
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`quotes or characterizes the cited webpages, Databricks denies the allegations in Paragraph 31.
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`7
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`32.
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`Paragraph 32 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 32.
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`33.
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`Paragraph 33 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 33.
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`34.
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`Paragraph 34 purports to quote and/or characterize the contents of Databricks
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`webpages, each of which speaks for itself. To the extent the Complaint incorrectly or incompletely
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`quotes or characterizes the cited webpage, Databricks denies the allegations in Paragraph 34.
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`35.
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`To the extent Paragraph 35 states a legal conclusion, no response is required. To
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`the extent the allegations in paragraph 35 purport to quote and/or characterize the contents of a
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`Databricks webpage, the document speaks for itself. To the extent the Complaint incorrectly or
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`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
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`Paragraph 35. Databricks denies the remaining allegations in paragraph 35, and specifically denies
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`that it has committed any acts of infringement.
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`36.
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`Paragraph 36 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
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`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 36.
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`37.
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`Paragraph 37 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
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`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 37.
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`8
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`38.
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`Paragraph 38 purports to quote and/or characterize the contents of a YouTube
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`video, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes or
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`characterizes the cited video, Databricks denies the allegations in Paragraph 38.
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`39.
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`Paragraph 39 purports to quote and/or characterize the contents of a YouTube
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`video, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes or
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`characterizes the cited video, Databricks denies the allegations in Paragraph 39.
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`40.
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`Paragraph 40 purports to quote and/or characterize the contents of Databricks
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`webpages, each of which speaks for itself. To the extent the Complaint incorrectly or incompletely
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`quotes or characterizes the cited webpages, Databricks denies the allegations in Paragraph 40.
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`41.
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`Paragraph 41 purports to quote and/or characterize the contents of Databricks
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`webpages, each of which speaks for itself. To the extent the Complaint incorrectly or incompletely
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`quotes or characterizes the cited webpage, Databricks denies the allegations in Paragraph 41.
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`42.
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`Paragraph 42 purports to quote and/or characterize the contents of Databricks
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`webpages, each of which speaks for itself. To the extent the Complaint incorrectly or incompletely
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`quotes or characterizes the cited webpage, Databricks denies the allegations in Paragraph 42.
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`43.
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`To the extent Paragraph 43 states a legal conclusion, no response is required.
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`Paragraph purports to quote and/or characterize the contents of a Databricks webpage, which
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`speaks for itself. To the extent the Complaint incorrectly or incompletely quotes or characterizes
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`the cited webpage, Databricks denies the allegations in Paragraph 43. Databricks denies the
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`remaining allegations in paragraph 43, and specifically denies that it has committed any acts of
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`infringement.
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`44.
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`Paragraph 44 purports to quote and/or characterize the contents of Databricks
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`webpages, each of which speaks for itself. To the extent the Complaint incorrectly or incompletely
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`9
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`quotes or characterizes the cited webpages, Databricks denies the allegations in Paragraph 44.
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`Databricks denies the remaining allegations in paragraph 44.
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`45.
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`Paragraph 45 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 45.
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`46.
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`Paragraph 46 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 46.
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`47.
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`Paragraph 47 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 47.
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`48.
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`Paragraph 48 purports to quote and/or characterize the contents of Databricks
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`webpages, each of which speaks for itself. To the extent the Complaint incorrectly or incompletely
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`quotes or characterizes the cited webpage, Databricks denies the allegations in Paragraph 48.
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`49.
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`To the extent Paragraph 49 states a legal conclusion, no response is required.
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`Paragraph 49 purport to quote and/or characterize the contents of Databricks webpages, each of
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`which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes or
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`characterizes the cited webpage, Databricks denies the allegations in Paragraph 49. Databricks
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`denies the remaining allegations in paragraph 49, and specifically denies that it has committed any
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`acts of infringement.
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`50.
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`Paragraph 50 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
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`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 50.
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`10
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`51.
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`Paragraph 51 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 51.
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`52.
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`Paragraph 52 purports to quote and/or characterize the contents of Databricks
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`webpages, each of which speaks for itself. To the extent the Complaint incorrectly or incompletely
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`quotes or characterizes the cited webpage, Databricks denies the allegations in Paragraph 52.
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`53.
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`Paragraph 53 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 53.
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`54.
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`Paragraph 54 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 54.
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`55.
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`Paragraph 55 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 55.
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`56.
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`To the extent Paragraph 56 states a legal conclusion, no response is required.
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`Paragraph 56 purports to quote and/or characterize the contents of Databricks webpages, each of
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`which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes or
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`characterizes the cited webpages, Databricks denies the allegations in Paragraph 56. Databricks
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`denies the remaining allegations in paragraph 56, and specifically denies that it has committed any
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`acts of infringement.
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`11
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`57.
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`Paragraph 57 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 57.
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`58.
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`Paragraph 58 purports to quote and/or characterize the contents of a Databricks
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`webpage or an Apache.org webpage, each of which speaks for itself. To the extent the Complaint
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`incorrectly or incompletely quotes or characterizes the cited webpage, Databricks denies the
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`allegations in Paragraph 58.
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`59.
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`Paragraph 59 purports to quote and/or characterize the contents of a zlib.net
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 59.
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`60.
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`Paragraph 60 purports to quote and/or characterize the contents of a Databricks
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`webpage or a Apache.org webpage, each of which speaks for itself. To the extent the Complaint
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`incorrectly or incompletely quotes or characterizes the cited webpage, Databricks denies the
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`allegations in Paragraph 60.
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`61.
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` Paragraph 61 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 61.
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`62.
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`To the extent Paragraph 62 states a legal conclusion, no response is required.
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`Paragraph 62 purports to quote and/or characterize the contents of a Databricks webpages, each of
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`which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes or
`
`characterizes the cited webpages, Databricks denies the allegations in Paragraph 62. Databricks
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`denies the remaining allegations in paragraph 62, and specifically denies that it has committed any
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`acts of infringement.
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`12
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`63.
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`Paragraph 63 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 63.
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`64.
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`Paragraph 64 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 64.
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`65.
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`Paragraph 65 purports to quote and/or characterize the contents of Databricks
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`webpages, each of which speaks for itself. To the extent the Complaint incorrectly or incompletely
`
`quotes or characterizes the cited webpages, Databricks denies the allegations in Paragraph 65.
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`66.
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`Paragraph 66 purports to quote and/or characterize the contents of a Databricks
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`webpage or a YouTube video, each of which speaks for itself. To the extent the Complaint
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`incorrectly or incompletely quotes or characterizes the cited webpage, Databricks denies the
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`allegations in Paragraph 66.
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`67.
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`Paragraph 67 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 67.
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`68.
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`To the extent Paragraph 68 states a legal conclusion, no response is required.
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`Paragraph 68 purports to quote and/or characterize the contents of a Databricks webpage, which
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`speaks for itself. To the extent the Complaint incorrectly or incompletely quotes or characterizes
`
`the cited webpage, Databricks denies the allegations in Paragraph 68. Databricks denies the
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`remaining allegations in paragraph 68, and specifically denies it has committed any acts of
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`infringement.
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`13
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`Case 2:24-cv-00162-JRG-RSP Document 12 Filed 05/03/24 Page 14 of 33 PageID #:
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`69.
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`Paragraph 69 purports to quote and/or characterize the contents of Databricks
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`webpages, each of which speaks for itself. To the extent the Complaint incorrectly or incompletely
`
`quotes or characterizes the cited webpage, Databricks denies the allegations in Paragraph 69.
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`70.
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`Paragraph 70 purports to quote and/or characterize the contents of a Databricks
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`webpage and a YouTube video, each of which speaks for itself. To the extent the Complaint
`
`incorrectly or incompletely quotes or characterizes the cited webpage and/or video, Databricks
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`denies the allegations in Paragraph 70.
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`71.
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`Paragraph 71 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in Paragraph 71.
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`72.
`
`Paragraph 72 purports to quote and/or characterize the contents of Databricks
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`webpages, each of which speaks for itself. To the extent the Complaint incorrectly or incompletely
`
`quotes or characterizes the cited webpages, Databricks denies the allegations in Paragraph 72.
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`73.
`
`Paragraph 73 purports to quote and/or characterize the contents of Databricks
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`webpages, each of which speaks for itself. To the extent the Complaint incorrectly or incompletely
`
`quotes or characterizes the cited webpages, Databricks denies the allegations in Paragraph 73.
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`COUNT I – ALLEGED INFRINGEMENT OF U.S. PATENT NO. 6,839,733
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`74.
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`Databricks admits that Byteweavr purports to incorporates paragraphs 1 through 74
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`by reference.
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`75.
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`Databricks admits that the ’733 patent is entitled “Network system extensible by
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`users.” Databricks lacks knowledge or information sufficient to admit or deny the remaining
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`allegations of paragraph 75 of the complaint and, on that basis, denies them.
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`76.
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`The allegations in this paragraph state a legal conclusion to which no response is
`
`required. To the extent a response is required, Databricks denies that the patent is valid.
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`Databricks admits that the ’733 patent lists U.S. Patent Application No. 09/712712 as its
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`application number. Databricks admits that the patent expired at least as early as October 23, 2018.
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`Databricks lacks knowledge or information sufficient to admit or deny the remaining allegations
`
`of paragraph 76 of the complaint and, on that basis, denies them.
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`77.
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`Databricks denies the allegations of paragraph 77 of the complaint, and specifically
`
`denies that it has committed any acts of infringement.
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`78.
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`Databricks admits that it designed and developed the Databricks Lakehouse
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`Platform. To the extent the Complaint alleges that Accused Instrumentalities include other
`
`products or services, such allegation is vague, and Databricks therefore lacks knowledge or
`
`information sufficient to admit or deny such allegation. Databricks denies the remaining
`
`allegations of paragraph 78 of the complaint.
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`79.
`
`Databricks denies the allegations in paragraph 79 and specifically denies that it has
`
`committed any acts of infringement.
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`80.
`
`Databricks denies the allegations of paragraph 80 of the complaint, and specifically
`
`denies that it has committed any acts of infringement.
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`81.
`
`Databricks denies the allegations of paragraph 81 of the complaint, and specifically
`
`denies that it has committed any acts of infringement.
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`82.
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`Databricks denies the allegations of paragraph 82 of the complaint, and specifically
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`denies that it has committed any acts of infringement.
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`83.
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`Databricks admits that Byteweavr filed this complaint on March 8, 2024. To the
`
`extent the allegations in paragraph 83 purport to quote or characterize the contents of the
`
`complaint, the document speaks for itself.
`
`84.
`
`Databricks denies the allegations of paragraph 84 of the complaint, and specifically
`
`denies that it has committed any acts of infringement.
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`COUNT II – ALLEGED INFRINGEMENT OF U.S. PATENT NO.7,949,752
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`85.
`
`Databricks admits that Byteweavr purports to incorporates paragraphs 1 through 85
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`by reference.
`
`86.
`
`Databricks admits that the ’752 patent is entitled “Network system extensible by
`
`users.” Databricks lacks knowledge or information sufficient to admit or deny the remaining
`
`allegations of paragraph 86 of the complaint and, on that basis, denies them.
`
`87.
`
`The allegations in this paragraph state a legal conclusion to which no response is
`
`required. To the extent a response is required, Databricks denies that the patent is valid.
`
`Databricks admits that the ’752 patent lists U.S. Patent Application No. 10/995,159 as its
`
`application number, and lists May 24, 2011 as its issue date. Databricks admits that the patent
`
`expired at least as early as August 13, 2022. Databricks lacks knowledge or information sufficient
`
`to admit or deny the remaining allegations of paragraph 87 of the complaint and, on that basis,
`
`denies them.
`
`88.
`
`Databricks denies the allegations of paragraph 88 of the complaint, and specifically
`
`denies that it has committed any acts of infringement.
`
`89.
`
`Databricks admits that it designed and developed the Databricks Lakehouse
`
`Platform. To the extent the Complaint alleges that Accused Instrumentalities include other
`
`products or services, such allegation is vague, and Databricks therefore lacks knowledge or
`
`
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`
`
`information sufficient to admit or deny such allegation. Databricks denies the remaining
`
`allegations of paragraph 89 of the complaint.
`
`90.
`
`Databricks denies the allegations in paragraph 90 and specifically denies that it has
`
`committed any acts of infringement.
`
`91.
`
`Databricks denies the allegations of paragraph 91 of the complaint, and sp