Case 2:24-cv-00162-JRG-RSP Document 37 Filed 08/05/24 Page 1 of 36 PageID #:
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`
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`BTYEWEAVR, LLC,
`
`
`Plaintiff,
`
`v.
`
`
`
`
`
`
`DATABRICKS, INC.,
`
`
`Civil Action No. 2:24-cv-00162-JRG-RSP
`
` JURY TRIAL DEMANDED
`
`Defendant.
`
`ANSWER OF DEFENDANT DATABRICKS, INC. TO PLAINTIFF’S
`FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT
`
`Defendant Databricks, Inc. (“Databricks”) hereby files its Answer and Affirmative
`
`Defenses to the First Amended Complaint (the “Amended Complaint”) of Plaintiff Byteweavr,
`
`LLC (“Byteweavr”). Each of the paragraphs below corresponds to the same numbered paragraph
`
`in the Amended Complaint. In responding to the Amended Complaint, Databricks has included
`
`several of Plaintiff’s headings for ease of reference, but in doing so, Databricks is not admitting to
`
`the accuracy of any statements made or agreeing with any characterizations made in such headings.
`
`Headings are used solely for organization and do not in any case act as an admission or statement.
`
`Databricks denies all allegations in the Amended Complaint, whether express or implied, that are
`
`not specifically admitted below. Databricks further denies that Byteweavr is entitled to the relief
`
`requested in the Amended Complaint, or to any other relief.
`
`THE PARTIES
`
`1.
`
`Databricks lacks sufficient information to form a belief as to the truth or falsity of
`
`the allegations of paragraph 1 of the Amended Complaint and, on that basis, denies them.
`
`
`
`
`458
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`BTYEWEAVR, LLC,
`
`
`Plaintiff,
`
`v.
`
`
`
`
`
`
`DATABRICKS, INC.,
`
`
`Civil Action No. 2:24-cv-00162-JRG-RSP
`
` JURY TRIAL DEMANDED
`
`Defendant.
`
`ANSWER OF DEFENDANT DATABRICKS, INC. TO PLAINTIFF’S
`FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT
`
`Defendant Databricks, Inc. (“Databricks”) hereby files its Answer and Affirmative
`
`Defenses to the First Amended Complaint (the “Amended Complaint”) of Plaintiff Byteweavr,
`
`LLC (“Byteweavr”). Each of the paragraphs below corresponds to the same numbered paragraph
`
`in the Amended Complaint. In responding to the Amended Complaint, Databricks has included
`
`several of Plaintiff’s headings for ease of reference, but in doing so, Databricks is not admitting to
`
`the accuracy of any statements made or agreeing with any characterizations made in such headings.
`
`Headings are used solely for organization and do not in any case act as an admission or statement.
`
`Databricks denies all allegations in the Amended Complaint, whether express or implied, that are
`
`not specifically admitted below. Databricks further denies that Byteweavr is entitled to the relief
`
`requested in the Amended Complaint, or to any other relief.
`
`THE PARTIES
`
`1.
`
`Databricks lacks sufficient information to form a belief as to the truth or falsity of
`
`the allegations of paragraph 1 of the Amended 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.
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`Databricks further admits that it is registered to do business in Texas, and that its registered agent
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`is United Agent Group Inc. Except as expressly admitted, Databricks denies the remaining
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`allegations in paragraph 2.
`
`3.
`
`Databricks admits that it was founded in 2013. To the extent the allegations in
`
`paragraph 3 purport to quote or characterize the contents of Databricks webpages, each document
`
`speaks for itself. To the extent the Amended Complaint incorrectly or incompletely quotes or
`
`characterizes the cited webpages, Databricks denies the allegations in paragraph 3. Databricks
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`lacks knowledge or information sufficient to admit or deny the remaining allegations of paragraph
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`3 of the Amended Complaint, and on that basis, denies them.
`
`4.
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`To the extent the allegations in paragraph 4 purport to quote or characterize the
`
`contents of Databricks webpages, each document speaks for itself. To the extent the Amended
`
`Complaint incorrectly or incompletely quotes or characterizes the cited webpages, Databricks
`
`denies the allegations in paragraph 4. Except as expressly admitted, Databricks denies the
`
`remaining allegations in paragraph 4.
`
`5.
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`To the extent the allegations in paragraph 5 purport to quote or characterize the
`
`contents of Databricks webpages, each document speaks for itself. To the extent the Amended
`
`Complaint incorrectly or incompletely quotes or characterizes the cited webpages, Databricks
`
`denies the allegations in paragraph 5. Databricks admits it published a blog entitled “What is a
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`Lakehouse” in 2020, in which “Lakehouse” was announced to the public. Except as expressly
`
`admitted, Databricks denies the remaining allegations in paragraph 5.
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`2
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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 Amended
`
`Complaint incorrectly or incompletely quotes or characterizes the cited webpages, Databricks
`
`denies the allegations in paragraph 6. Except as expressly admitted, Databricks denies the
`
`remaining allegations in paragraph 6.
`
`7.
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`To the extent the allegations in paragraph 7 purport to quote or characterize the
`
`contents of Databricks webpages, each document speaks for itself. To the extent the Amended
`
`Complaint incorrectly or incompletely quotes or characterizes the cited webpages, Databricks
`
`denies the allegations in paragraph 7. Except as expressly admitted, Databricks denies the
`
`remaining 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
`
`of a Databricks webpage, the document speaks for itself. To the extent the Amended Complaint
`
`incorrectly or incompletely quotes or characterizes the cited webpage, Databricks denies the
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`allegations in paragraph 8. Except as expressly admitted, Databricks denies the remaining
`
`allegations in 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
`
`required. To the extent a response is deemed required, Databricks admits that the Amended
`
`Complaint purports to allege that this civil action arises under the Patent Laws of the United States,
`
`35 U.S.C. §§ 271, 281, and 284-285, but denies that the allegations have any merit or that Plaintiff
`
`is entitled to any relief.
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`3
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`10.
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`Databricks admits that this Court has subject matter jurisdiction over infringement
`
`claims brought by the owner or exclusive licensee of a patent pursuant to 28 U.S.C. §§ 1331 and
`
`1338(a), but Databricks lacks knowledge and information sufficient to form a belief as to whether
`
`Plaintiff is the owner or exclusive licensee of the patents in suit.
`
`11.
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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 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.
`
`12.
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`To the extent the allegations in paragraph 12 purport to quote or characterize the
`
`contents of a Databricks webpage, the document speaks for itself. To the extent the Amended
`
`Complaint incorrectly or incompletely quotes or characterizes the cited webpage, Databricks
`
`denies the allegations in paragraph 12. Except as expressly admitted, Databricks denies the
`
`remaining allegations in paragraph 12.
`
`13.
`
`Databricks denies the allegations of paragraph 13 of the Amended Complaint.
`
`Databricks 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
`
`required. To the extent a response is deemed to be required, Databricks admits that this Court has
`
`personal jurisdiction over Databricks with respect to the instant action. Databricks denies that it
`
`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
`
`Databricks webpage, the document speaks for itself. To the extent the Amended Complaint
`
`incorrectly or incompletely quotes or characterizes the cited webpage, Databricks denies the
`
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`4
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`Case 2:24-cv-00162-JRG-RSP Document 37 Filed 08/05/24 Page 5 of 36 PageID #:
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`allegations in paragraph 14. Databricks denies the remaining allegations in paragraph 14, and
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`specifically denies 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
`
`contents of Databricks webpages and/or a Federal Circuit Court case law, or an Eastern District of
`
`Texas case law, the document speaks for itself. To the extent the Amended Complaint incorrectly
`
`or incompletely quotes or characterizes the cited documents, Databricks denies the allegations in
`
`paragraph 15. The allegations in this paragraph state a legal conclusion to which no response is
`
`required. Databricks denies the remaining allegations in paragraph 15, and specifically denies that
`
`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
`
`required. To the extent a response is deemed to be required, Databricks does not dispute, for this
`
`action only, that venue is authorized in this District pursuant to 28 U.S.C. § 1400(b) and that this
`
`Court has personal jurisdiction over it with respect to the instant action. By filing this answer,
`
`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
`
`in the interest of justice. Databricks denies the remaining allegations in paragraph 16, and
`
`specifically denies that it has committed any acts of infringement.
`
`17.
`
`The allegations in this paragraph state a legal conclusion to which no response is
`
`required. To the extent a response is deemed to be required, Databricks does not dispute, for this
`
`action only, that venue is authorized in this District pursuant to 28 U.S.C. § 1400(b) and that this
`
`Court has personal jurisdiction over it with respect to the instant action. Databricks specifically
`
`denies that venue is convenient in this District and reserves all right to contend that this action
`
`should be transferred to another district for the convenience of the parties and witnesses and in the
`
`
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`5
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`Case 2:24-cv-00162-JRG-RSP Document 37 Filed 08/05/24 Page 6 of 36 PageID #:
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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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`THE ASSERTED PATENT AND TECHNOLOGY
`
`18.
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`To the extent paragraph 18 states a legal conclusion, no response is required.
`
`Databricks lacks knowledge or information sufficient to admit or deny the allegations of paragraph
`
`18 of the Amended Complaint and, on that basis, denies them.
`
`19.
`
`Databricks lacks knowledge or information sufficient to admit or deny the
`
`allegations of paragraph 19 of the Amended 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
`
`allegations of paragraph 20 of the Amended 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
`
`allegations of paragraph 21 of the Amended Complaint and, on that basis, denies them.
`
`22.
`
`Databricks lacks knowledge or information sufficient to admit or deny the
`
`allegations of paragraph 22 of the Amended 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
`
`allegations of paragraph 23 of the Amended Complaint and, on that basis, denies them.
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`24.
`
`Databricks lacks knowledge or information sufficient to admit or deny the
`
`allegations of paragraph 24 of the Amended 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
`
`allegations of paragraph 25 of the Amended Complaint and, on that basis, denies them.
`
`26.
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`To the extent the allegations in paragraph 26 purport to quote or characterize the
`
`contents of a Databricks webpage, the document speaks for itself. To the extent the Amended
`
`Complaint incorrectly or incompletely quotes or characterizes the cited webpage, Databricks
`
`
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`6
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`denies the allegations in paragraph 26. Except as expressly admitted, Databricks denies the
`
`remaining allegations in paragraph 26.
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`27.
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`To the extent paragraph 27 states a legal conclusion, no response is required. To
`
`the extent the allegations in paragraph 27 purport to quote or characterize the contents of a
`
`Databricks webpage, the document speaks for itself. To the extent the Amended Complaint
`
`incorrectly or incompletely quotes or characterizes the cited webpages, Databricks denies the
`
`allegations in paragraph 27. Databricks admits that it designed and developed the Databricks
`
`Lakehouse Platform. Databricks denies the remaining allegations in paragraph 27, and specifically
`
`denies that it has committed any acts of infringement.
`
`28.
`
`Databricks denies the allegations of paragraph 28 of the Amended Complaint, and
`
`specifically denies that it has committed any acts of infringement.
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`29.
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`To the extent paragraph 29 states a legal conclusion, no response is required.
`
`paragraph 29 purports to quote and/or characterize the contents of Databricks webpages, each of
`
`which speaks for itself. To the extent the Amended Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpages, Databricks denies the allegations in paragraph 29. Databricks
`
`denies the remaining allegations in paragraph 29, and specifically denies that it has committed any
`
`acts of infringement.
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`30.
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`To the extent paragraph 30 states a legal conclusion, no response is required.
`
`Paragraph 30 purports to quote and/or characterize the contents of Databricks webpages, each of
`
`which speaks for itself. To the extent the Amended Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpages, Databricks denies the allegations in paragraph 30. Databricks
`
`denies the remaining allegations in paragraph 30, and specifically denies that it has committed any
`
`acts of infringement.
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`7
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`31.
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`The allegations in this paragraph state a legal conclusion to which no response is
`
`required. Databricks denies the allegations in paragraph 31. Databricks specifically denies that it
`
`has committed any acts of infringement.
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`32.
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` To the extent paragraph 32 states a legal conclusion, no response is required.
`
`Paragraph 32 purports to quote and/or characterize the contents of Databricks webpages, each of
`
`which speaks for itself. To the extent the Amended Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpages, Databricks denies the allegations in paragraph 32. Databricks
`
`denies the remaining allegations in paragraph 32, and specifically denies that it has committed any
`
`acts of infringement.
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`33.
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`Paragraph 33 purports to quote and/or characterize the contents of a Databricks
`
`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 33. Databricks specifically denies that it has committed any acts of infringement.
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`34.
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`Paragraph 34 purports to quote and/or characterize the contents of a Databricks
`
`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 34.
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`35.
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`Paragraph 35 purports to quote and/or characterize the contents of Databricks
`
`webpages, each of which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpages, Databricks denies the allegations in
`
`paragraph 35.
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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 Amended Complaint incorrectly or
`
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`8
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`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 36. Databricks specifically denies that it has committed any acts of infringement.
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`37.
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`Paragraph 37 purports to quote and/or characterize the contents of a Databricks
`
`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 37.
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`38.
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`Paragraph 38 purports to quote and/or characterize the contents of Databricks
`
`webpages, each of which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 38.
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`39.
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`To the extent paragraph 39 states a legal conclusion, no response is required. To
`
`the extent the allegations in paragraph 39 purport to quote and/or characterize the contents of a
`
`Databricks webpage, the document speaks for itself. To the extent the Amended Complaint
`
`incorrectly or incompletely quotes or characterizes the cited webpage, Databricks denies the
`
`allegations in paragraph 39. Databricks denies the remaining allegations in paragraph 39, and
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`specifically denies that it has committed any acts of infringement.
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`40.
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`Paragraph 40 also purports to quote and/or characterize the contents of a Databricks
`
`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 40. Databricks specifically denies that it has committed any acts of infringement.
`
`41.
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`Paragraph 41 purports to quote and/or characterize the contents of a Databricks
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`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
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`9
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`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
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`paragraph 41.
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`42.
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`Paragraph 42 also purports to quote and/or characterize the contents of a Databricks
`
`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 42. Databricks specifically denies that it has committed any acts of infringement.
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`43.
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`Paragraph 43 purports to quote and/or characterize the contents of a YouTube
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`video, which speaks for itself. To the extent the Amended Complaint incorrectly or incompletely
`
`quotes or characterizes the cited video, Databricks denies the allegations in paragraph 43.
`
`44.
`
`Paragraph 44 purports to quote and/or characterize the contents of Databricks
`
`webpages, each of which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpages, Databricks denies the allegations in
`
`paragraph 44.
`
`45.
`
`Paragraph 45 purports to quote and/or characterize the contents of Databricks
`
`webpages, each of which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 45.
`
`46.
`
`Paragraph 46 also purports to quote and/or characterize the contents of a Databricks
`
`webpages, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 46. Databricks specifically denies that it has committed any acts of infringement.
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`47.
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`To the extent Paragraph 47 states a legal conclusion, no response is required.
`
`Paragraph 47 purports to quote and/or characterize the contents of a Databricks webpage, which
`
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`10
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`speaks for itself. To the extent the Amended Complaint incorrectly or incompletely quotes or
`
`characterizes the cited webpage, Databricks denies the allegations in paragraph 47. Databricks
`
`denies the remaining allegations in paragraph 47, and specifically denies that it has committed any
`
`acts of infringement.
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`48.
`
`Paragraph 48 purports to quote and/or characterize the contents of Databricks
`
`webpages, each of which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpages, Databricks denies the allegations in
`
`paragraph 48. Databricks denies the remaining allegations in paragraph 48.
`
`49.
`
`Paragraph 49 purports to quote and/or characterize the contents of Databricks
`
`webpages, each of which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpages, Databricks denies the allegations in
`
`paragraph 49. Databricks specifically denies that it has committed any acts of infringement.
`
`50.
`
`Paragraph 50 purports to quote and/or characterize the contents of a Databricks
`
`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 50.
`
`51.
`
`Paragraph 51 purports to quote and/or characterize the contents of a Databricks
`
`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 51.
`
`52.
`
`Paragraph 52 purports to quote and/or characterize the contents of Databricks
`
`webpages, each of which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`
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`11
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`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
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`paragraph 52.
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`53.
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`To the extent paragraph 53 states a legal conclusion, no response is required.
`
`Paragraph 53 purport to quote and/or characterize the contents of Databricks webpages, each of
`
`which speaks for itself. To the extent the Amended Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpage, Databricks denies the allegations in paragraph 53. Databricks
`
`denies the remaining allegations in paragraph 53, and specifically denies that it has committed any
`
`acts of infringement.
`
`54.
`
`Paragraph 54 also purports to quote and/or characterize the contents of a Databricks
`
`webpages, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 54. Databricks specifically denies that it has committed any acts of infringement.
`
`55.
`
`Paragraph 55 purports to quote and/or characterize the contents of a Databricks
`
`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 55.
`
`56.
`
`Paragraph 56 purports to quote and/or characterize the contents of Databricks
`
`webpages, each of which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 56.
`
`57.
`
`Paragraph 57 purports to quote and/or characterize the contents of a Databricks
`
`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`
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`12
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`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 57.
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`58.
`
`Paragraph 58 purports to quote and/or characterize the contents of a Databricks
`
`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 58.
`
`59.
`
`Paragraph 59 purports to quote and/or characterize the contents of a Databricks
`
`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 59.
`
`60.
`
`To the extent paragraph 60 states a legal conclusion, no response is required.
`
`Paragraph 60 purports to quote and/or characterize the contents of Databricks webpages, each of
`
`which speaks for itself. To the extent the Amended Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpages, Databricks denies the allegations in paragraph 60. Databricks
`
`denies the remaining allegations in paragraph 60, and specifically denies that it has committed any
`
`acts of infringement.
`
`61.
`
`Paragraph 61 purports to quote and/or characterize the contents of a Databricks
`
`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 61.
`
`62.
`
`Paragraph 62 purports to quote and/or characterize the contents of a Databricks
`
`webpage or an Apache.org webpage, each of which speaks for itself. To the extent the Amended
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`13
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`Case 2:24-cv-00162-JRG-RSP Document 37 Filed 08/05/24 Page 14 of 36 PageID #:
`471
`
`
`
`Complaint incorrectly or incompletely quotes or characterizes the cited webpage, Databricks
`
`denies the allegations in paragraph 62.
`
`63.
`
`Paragraph 63 purports to quote and/or characterize the contents of a zlib.net
`
`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 63.
`
`64.
`
`Paragraph 64 purports to quote and/or characterize the contents of a Databricks
`
`webpage or a Apache.org webpage, each of which speaks for itself. To the extent the Amended
`
`Complaint incorrectly or incompletely quotes or characterizes the cited webpage, Databricks
`
`denies the allegations in paragraph 64.
`
`65.
`
` Paragraph 65 purports to quote and/or characterize the contents of a Databricks
`
`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 65.
`
`66.
`
`To the extent paragraph 66 states a legal conclusion, no response is required.
`
`Paragraph 66 purports to quote and/or characterize the contents of a Databricks webpages, each of
`
`which speaks for itself. To the extent the Amended Complaint incorrectly or incompletely quotes
`
`or characterizes the cited webpages, Databricks denies the allegations in paragraph 66. Databricks
`
`denies the remaining allegations in paragraph 66, and specifically denies that it has committed any
`
`acts of infringement.
`
`67.
`
`Paragraph 67 purports to quote and/or characterize the contents of a Databricks
`
`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`
`
`14
`
`
`
`Case 2:24-cv-00162-JRG-RSP Document 37 Filed 08/05/24 Page 15 of 36 PageID #:
`472
`
`
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 67.
`
`68.
`
`Paragraph 68 purports to quote and/or characterize the contents of a Databricks
`
`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 68.
`
`69.
`
`Paragraph 69 purports to quote and/or characterize the contents of Databricks
`
`webpages, each of which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpages, Databricks denies the allegations in
`
`paragraph 69.
`
`70.
`
`Paragraph 70 purports to quote and/or characterize the contents of a Databricks
`
`webpage or a YouTube video, each of which speaks for itself. To the extent the Amended
`
`Complaint incorrectly or incompletely quotes or characterizes the cited webpage, Databricks
`
`denies the allegations in paragraph 70.
`
`71.
`
`Paragraph 71 purports to quote and/or characterize the contents of a Databricks
`
`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 71.
`
`72.
`
`To the extent paragraph 72 states a legal conclusion, no response is required.
`
`Paragraph 72 purports to quote and/or characterize the contents of a Databricks webpage, which
`
`speaks for itself. To the extent the Amended Complaint incorrectly or incompletely quotes or
`
`characterizes the cited webpage, Databricks denies the allegations in paragraph 72. Databricks
`
`
`
`15
`
`
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`Case 2:24-cv-00162-JRG-RSP Document 37 Filed 08/05/24 Page 16 of 36 PageID #:
`473
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`
`
`denies the remaining allegations in paragraph 72, and specifically denies it has committed any acts
`
`of infringement.
`
`73.
`
`Paragraph 73 also purports to quote and/or characterize the contents of a Databricks
`
`webpages, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 73. Databricks specifically denies that it has committed any acts of infringement.
`
`74.
`
`Paragraph 74 purports to quote and/or characterize the contents of a Databricks
`
`webpage and a YouTube video, each of which speaks for itself. To the extent the Amended
`
`Complaint incorrectly or incompletely quotes or characterizes the cited webpage and/or video,
`
`Databricks denies the allegations in paragraph 74.
`
`75.
`
`Paragraph 75 also purports to quote and/or characterize the contents of a Databricks
`
`webpage, which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpage, Databricks denies the allegations in
`
`paragraph 75. Databricks specifically denies that it has committed any acts of infringement.
`
`76.
`
`Paragraph 76 purports to quote and/or characterize the contents of Databricks
`
`webpages, each of which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpages, Databricks denies the allegations in
`
`paragraph 76.
`
`77.
`
`Paragraph 77 purports to quote and/or characterize the contents of Databricks
`
`webpages, each of which speaks for itself. To the extent the Amended Complaint incorrectly or
`
`incompletely quotes or characterizes the cited webpages, Databricks denies the allegations in
`
`paragraph 77.
`
`
`
`16
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`
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`Case 2:24-cv-00162-JRG-RSP Document 37 Filed 08/05/24 Page 17 of 36 PageID #:
`474
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`
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`COUNT I – ALLEGED INFRINGEMENT OF U.S. PATENT NO. 6,839,733
`
`78.
`
`Databricks admits that Byteweavr purports to incorporate paragraphs 1 through 77
`
`by reference.
`
`79.
`
`Databricks admits that the ’733 patent is entitled “Network system extensible by
`
`users.” Databricks lacks knowledge or information sufficient to admit or deny the remaining
`
`allegations of paragraph 79 of the Amended Complaint and, on that basis, denies them.
`
`80.
`
`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 ’733 patent lists U.S. Patent Application No. 09/712,712 as its
`
`application number. Databricks admits that the patent expired at least as early as October 23, 2018.
`
`Databricks lacks knowledge or information sufficient to admit or deny the remaining allegations
`
`of paragraph 80 of the Amended Complaint and, on that basis, denies them.
`
`81.
`
`Databricks denies the allegations of paragraph 81 of the Amended Complaint, and
`
`specifically denies that it has committed any acts of infringement.
`
`82.
`
`Databricks admits that it designed and developed the Databricks Lakehouse
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`Platform. To the extent the Amended 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 allega
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