Case 4:23-cv-01147-ALM Document 16 Filed 03/08/24 Page 1 of 13 PageID #: 132
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
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`R2 SOLUTIONS LLC,
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`Plaintiff,
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`v.
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`DATABRICKS, INC.,
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`Defendant.
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`Civil Action No. 4:23-cv-01147-ALM
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` JURY TRIAL DEMANDED
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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 R2 Solutions LLC (“R2”). Each of the paragraphs below
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`corresponds to the same numbered paragraph in the complaint. In responding to the complaint,
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`Databricks has included several of Plaintiff’s headings for ease of reference, but in doing so,
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`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 Plaintiff 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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`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 it is a corporation
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`1
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`organized under the laws of the state of Delaware, with a principal place of business of 160 Spear
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`Street, Suite 1300, San Francisco, CA 94105. Databricks further admits 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.
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`ALLEGED JURISDICTION AND VENUE
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`3.
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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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`§ 101 et seq., including without limitation 35 U.S.C. § 271 et seq., but denies that the allegations
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`have any merit or that Plaintiff is entitled to any relief. Databricks admits that this Court has
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`subject matter jurisdiction over infringement claims brought by the owner or exclusive licensee of
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`a patent pursuant to 28 U.S.C. §§ 1331 and 1338(a).
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`4.
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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. To the extent the
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`allegations in paragraph 4 purport to quote or characterize the contents of the Texas Civil Practice
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`and Remedies Code, a Databricks webpage and/or LinkedIn webpages, the documents speak for
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`themselves. Databricks denies that it has committed or is committing any acts of infringement
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`anywhere, including in this District. Except as expressly admitted, Databricks denies the
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`remaining 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 a LinkedIn webpage, the document speaks for itself. Databricks denies the remaining
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`allegations in paragraph 5.
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`2
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`6.
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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. To the extent the
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`allegations in paragraph 6 purport to quote or characterize the contents of a Databricks webpage,
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`the document speaks for itself. Databricks denies that it has committed or is committing any acts
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`of infringement anywhere, including in this District. Except as expressly admitted, Databricks
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`denies the remaining allegations of paragraph 6 of the complaint.
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`7.
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`8.
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`9.
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`Databricks denies the allegations of paragraph 7 of the complaint.
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`Databricks denies the allegations of paragraph 8 of the complaint.
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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 9, and
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`specifically denies that it has committed any acts of infringement.
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`BACKGROUND
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`10.
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`Databricks lacks knowledge or information sufficient to admit or deny the
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`allegations of paragraph 10 of the complaint and, on that basis, denies them.
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`11.
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`Databricks lacks knowledge or information sufficient to admit or deny the
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`allegations of paragraph 11 of the complaint and, on that basis, denies them.
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`3
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`12.
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`Databricks lacks knowledge or information sufficient to admit or deny the
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`allegations of paragraph 12 of the complaint and, on that basis, denies them.
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`THE PATENT-IN-SUIT
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`13.
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`Databricks admits that U.S. Patent No. 8,190,610 (the “’610 patent”) lists
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`“MapReduce for distributing database processing” as its title and May 29, 2012 as its issue date.
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`Databricks further admits that R2 purports to attach a copy of the ’610 patent to the complaint.
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`Databricks lacks sufficient information to form a belief as to the truth or falsity of the remaining
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`allegations of paragraph 13 of the complaint and, on that basis, denies them.
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`14.
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`Databricks lacks knowledge or information sufficient to admit or deny the
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`allegations of paragraph 14 of the complaint and, on that basis, denies them.
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`15.
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`16.
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`Databricks denies the allegations of paragraph 15.
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`Databricks denies that the ’610 patent provides any technological improvement. To
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`the extent the allegations in paragraph 16 purport to quote or characterize the contents of the ’610
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`patent, the document speaks for itself. Databricks denies the remaining allegations of paragraph
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`16.
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`17.
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`Databricks denies that the ’610 patent provides any technological advantages. To
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`the extent the allegations in paragraph 17 purport to quote or characterize the contents of the ’610
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`patent, the document speaks for itself. Databricks denies the remaining allegations of paragraph
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`17.
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`18.
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`Databricks denies that claim 1 of the ’610 patent provides a patentable solution. To
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`the extent the allegations in paragraph 18 purport to quote or characterize the contents of the ’610
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`patent, the document speaks for itself. Databricks denies the remaining allegations of paragraph
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`18.
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`19.
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`Databricks denies that the ’610 patent provides a novel or technological
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`improvement in computer capabilities. To the extent the allegations in paragraph 19 purport to
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`quote or characterize the contents of the ’610 patent, the document speaks for itself. Databricks
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`denies the remaining allegations of paragraph 19.
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`20.
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`Databricks denies that the purported invention of the ’610 patent provides an
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`improvement in computer functionality. To the extent the allegations in paragraph 20 purport to
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`quote or characterize the contents of the ’610 patent, the document speaks for itself. Databricks
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`denies the remaining allegations of paragraph 20.
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`21.
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`To the extent the allegations in paragraph 21 purport to quote or characterize the
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`contents of the ’610 patent, the document speaks for itself. Databricks denies the remaining
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`allegations of paragraph 21.
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`22.
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`Databricks denies the allegations of paragraph 22.
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`DEFENDANT’S ALLEGED PRE-SUIT KNOWLEDGE
`OF THE ALLEGED INFRINGEMENT
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`Databricks denies the allegations in paragraph 23.
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`Databricks lacks sufficient information to form a belief as to the truth or falsity of
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`23.
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`24.
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`the allegations of paragraph 24 of the complaint and, on that basis, denies them.
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`25.
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`To the extent the allegations in paragraph 25 purport to quote or characterize the
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`contents of the subpoena, the document speaks for itself. Databricks lacks sufficient information
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`to form a belief as to the truth or falsity of the remaining allegations of paragraph 25 of the
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`complaint and, on that basis, denies them.
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`26.
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`Databricks specifically denies that it has committed or is committing any acts of
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`infringement. Databricks denies the remaining allegations in paragraph 26 of the complaint.
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`COUNT I – ALLEGED INFRINGEMENT OF U.S. PATENT NO. 8,190,610
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`5
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`27.
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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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`§ 101 et seq., including without limitation 35 U.S.C. § 271 et seq., but denies that the allegations
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`have any merit or that Plaintiff is entitled to any relief.
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`28.
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`Databricks lacks knowledge or information sufficient to admit or deny the
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`allegations of paragraph 28 of the complaint and, on that basis, denies them.
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`29.
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`Databricks denies the allegations of paragraph 29 of the complaint.
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`Alleged Direct Infringement (35 U.S.C. § 271 (a))
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`30.
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`31.
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`32.
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`Databricks denies the allegations of paragraph 30 of the complaint.
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`Databricks denies the allegations of paragraph 31 of the complaint.
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`To the extent the allegations in paragraph 32 purport to quote or characterize the
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`contents of a Databricks webpage, the document speaks for itself. Databricks denies the remaining
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`allegations of paragraph 32 of the complaint. Databricks specifically denies that it has committed
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`or is committing any acts of infringement anywhere, including in this District.
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`33.
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`Databricks admits that it makes and uses the Databricks Data Intelligence
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`Platform/Databricks Lakehouse Platform. Databricks specifically denies that any of its products
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`or services infringe. Databricks denies the remaining allegations of paragraph 33 of the complaint.
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`34.
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`Databricks denies the allegations of paragraph 34 of the complaint.
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`Alleged Indirect Infringement (Inducement — 35 U.S.C. § 271(b))
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`35.
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`36.
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`Databricks denies the allegations of paragraph 35 of the complaint.
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`Databricks specifically denies that it has committed or is committing any acts of
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`infringement. Databricks denies the remaining allegations in paragraph 36 of the complaint.
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`6
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`37.
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`38.
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`Databricks denies the allegations of paragraph 37 of the complaint.
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`To the extent the allegations in paragraph 38 purport to quote or characterize the
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`contents of a Databricks webpage, the document speaks for itself. Databricks denies the remaining
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`allegations of paragraph 38 of the complaint.
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`39.
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`To the extent the allegations in paragraph 39 purport to quote or characterize the
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`contents of a Databricks webpage, the document speaks for itself. Databricks denies the remaining
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`allegations of paragraph 39 of the complaint.
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`40.
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`To the extent the allegations in paragraph 40 purport to quote or characterize the
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`contents of Databricks webpages, the documents speak for themselves. Databricks denies the
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`remaining allegations of paragraph 40 of the complaint. Databricks specifically denies that it has
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`committed or is committing any acts of infringement.
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`41.
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`To the extent the allegations in paragraph 41 purport to quote or characterize the
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`contents of Databricks webpages, the documents speak for themselves. Databricks denies the
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`remaining allegations of paragraph 41 of the complaint. Databricks specifically denies that it has
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`committed or is committing any acts of infringement.
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`Alleged Damages
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`42.
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`43.
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`Databricks denies the allegations of paragraph 42.
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`Databricks denies the allegations of paragraph 43.
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`PRAYER FOR RELIEF
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`Databricks denies that R2 is entitled to any of the relief requested in the complaint or any
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`relief whatsoever. Databricks denies all allegations in the complaint that have not been specifically
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`admitted in paragraphs 1-43 above.
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`DEMAND FOR A JURY TRIAL
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`R2’s demand for a jury trial does not require a response.
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`7
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`AFFIRMATIVE AND OTHER DEFENSES
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`Databricks asserts the following additional defenses to the complaint. In doing so,
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`Databricks does not assume any burden of proof on any issue that is R2’s burden as a matter of
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`law. Databricks also reserves the right to amend or supplement these defenses as additional facts
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`become known.
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`FIRST DEFENSE: FAILURE TO STATE A CAUSE OF ACTION
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`The complaint fails to allege facts sufficient to state a cause of action upon which relief
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`may be granted.
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`SECOND DEFENSE: NON-INFRINGEMENT (’610 PATENT)
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`Databricks has not infringed, and currently does not infringe, any claim of the ’610 patent
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`and is not liable for any infringement.
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`THIRD DEFENSE: INVALIDITY AND INELIGIBILITY (’610 PATENT)
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`The ’610 patent is invalid for failure to meet one or more of the conditions for patentability
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`specified in Title 35, U.S.C., or the rules, regulations, and law related thereto, including, without
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`limitation, 35 U.S.C. §§ 101, 102, 103, and/or 112.
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`FOURTH DEFENSE: PROSECUTION HISTORY ESTOPPEL/DISCLAIMER
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`The relief sought by R2 is barred, in whole or in part, under the doctrine of prosecution
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`history estoppel and/or disclaimer, due to amendments and/or statements made during prosecution
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`of the ’610 patent.
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`FIFTH DEFENSE: ENSNAREMENT
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`R2 cannot assert any claims for patent infringement under the doctrine of equivalents
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`because such an asserted scope of equivalency would encompass or ensnare the prior art.
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`SIXTH DEFENSE: DEDICATION TO THE PUBLIC
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`The relief sought by R2 is barred, in whole or in part, because R2 and/or predecessors in
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`interest of the Asserted Patent dedicated to the public all methods, systems, and products disclosed
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`in the ’610 patent, but not literally claimed therein.
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`SEVENTH DEFENSE: LIMITATION ON DAMAGES AND COSTS
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`R2’s claim for damages is barred, in whole or in part, by 35 U.S.C. §§ 286 or 287. To the
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`extent any claim of the ’610 patent is invalid, R2 is barred from recovering costs by 35 U.S.C.
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`§ 288.
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`EIGTH DEFENSE: GOOD FAITH
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`Databricks has engaged in all relevant activities in good faith, thereby precluding R2, even
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`if it prevails, from recovering its reasonable attorneys’ fees or costs under 35 U.S.C. § 285.
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`NINTH DEFENSE: EQUITABLE DEFENSES
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`R2’s claims against Databricks are barred, in whole or in part, by the doctrines of waiver,
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`patent misuse, implied waiver, acquiescence, legal estoppel, equitable estoppel, unclean hands,
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`and/or other equitable defenses.
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`TENTH DEFENSE: LICENSE AND PATENT EXHAUSTION
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`R2’s claims against Databricks are barred, in whole or in part, by express or implied
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`licenses to the Patent-in-Suit, and/or under the doctrines of patent exhaustion, first sale and/or the
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`single recovery rule.
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`ELEVENTH DEFENSE: CONTRACTUAL LIMITATION ON DAMAGES
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`R2’s claims for monetary relief are limited to the extent it or any predecessor-in-interest to
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`the Patent-in-Suit undertook an obligation to license the Patent-in-Suit on fair, reasonable, and/or
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`non-discriminatory terms.
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`TWELFTH DEFENSE: NO EXCEPTIONAL CASE
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`R2 cannot show that any acts or omissions by Databricks render this an exceptional case
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`justifying an award of attorney fees against Databricks pursuant to 35 U.S.C. § 285.
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`THIRTEENTH DEFENSE: NO WILLFUL INFRINGEMENT
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`R2 is not entitled to enhanced or increased damages for willful infringement because
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`Databricks has not engaged in any conduct that meets the applicable standard for willful
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`infringement.
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`RESERVATION OF ADDITIONAL DEFENSES
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`Databricks reserves the right to assert additional defenses in the event that discovery or
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`other analysis indicates that additional defenses are appropriate.
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`JURY DEMAND
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`Databricks hereby requests a trial by jury on all issues so triable including specifically on
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`R2’s claims and Databricks’ defenses thereto.
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`PRAYER FOR RELIEF
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`Databricks prays for judgment with respect to R2’s complaint and Databricks’ defenses as
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`follows:
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`a.
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`A judgment in favor of Databricks denying R2 any relief requested in its complaint
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`and dismissing its complaint with prejudice;
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`b.
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`A judgment against R2 finding that Databricks has not and does not infringe and is
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`not liable for any infringement of any claim of the ’610 patent;
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`c.
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`d.
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`A judgment against R2 finding that the ’610 patent is invalid;
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`A judgment that this is an exceptional case within the meaning of 35 U.S.C. § 285
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`and awarding Databricks its reasonable attorneys’ fees;
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`e.
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`f.
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`An award of costs to Databricks; and
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`Such other relief as the Court shall deem just and proper.
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`Dated: March 8, 2024
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`Respectfully submitted,
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`/s/ Michael J. Sacksteder
`Michael J. Sacksteder
`CA Bar No. 191605 (Admitted E.D. Texas)
`Email: msacksteder@fenwick.com
`Dargaye Churnet
`CA Bar No. 303659 (Admitted E.D. Texas)
`Email: dchurnet@fenwick.com
`Gregory Sefian
`CA Bar No. 341802 (Admitted Pro Hac Vice)
`Email: gsefian@fenwick.com
`Su Li
`CA Bar No. 339374 (Admitted Pro Hac Vice)
`Email: sli@fenwick.com
`FENWICK & WEST LLP
`555 California Street, 12th Floor
`San Francisco, California 94104
`Telephone:
`415.875.2300
`Facsimile:
`415.281.1350
`
`Vigen Salmastlian
`CA Bar No. 276846 (Admitted E.D. Texas)
`Email: vsalmastlian@fenwick.com
`FENWICK & WEST LLP
`801 California Street,
`Mountain View, CA 94041
`Telephone:
`650.988.8500
`Facsimile:
`650.938.5200
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`Jessica M. Kaempf
`WA Bar No. 51666 (Admitted E.D. Texas)
`Email: jkaempf@fenwick.com
`FENWICK & WEST LLP
`401 Union Street, 5th Floor
`Seattle, WA 98101
`Telephone:
`206.389.4510
`Facsimile:
`206.389.4511
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`Attorneys for Defendant
`Databricks, Inc.
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`CERTIFICATE OF SERVICE
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`I hereby certify that all counsel of record who consented to electronic service are being
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`served with a copy of this document via electronic mail per Local Rule CV-5 on March 8, 2024.
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`/s/ Michael J. Sacksteder
`Michael J. Sacksteder
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