Case 5:23-cv-00152-RWS Document 13 Filed 04/23/24 Page 1 of 36 PageID #: 323
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`MAXELL, LTD.,
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`Plaintiff,
`
`v.
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`LG ELECTRONICS INC. and
`LG ELECTRONICS U.S.A., INC.,
`
`Defendants.
`
`Civil No. 5:23-cv-00152-RWS
`
`JURY TRIAL REQUESTED
`
`DEFENDANTS’ ANSWER TO PLAINTIFF’S
`COMPLAINT FOR PATENT INFRINGEMENT
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`Defendants LG Electronics Inc. (“LGE”) and LG Electronics U.S.A., Inc. (“LGEUS”)
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`(collectively, “Defendants” or “LG”), by and through their attorneys, file this Answer to Plaintiff
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`Maxell, Ltd.’s (“Plaintiff” or “Maxell”) Complaint for Patent Infringement (“Complaint”). The
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`numbered paragraphs in this Answer correspond to the like-numbered paragraphs of the
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`Complaint, to the extent applicable. LG denies all allegations and characterizations except those
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`specifically admitted.
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`Specifically, LG answers as follows:
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`OVERVIEW1
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`1.
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`LG admits that Plaintiff’s Complaint purports to state a cause of action for patent
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`infringement, but LG denies that it has committed any acts of patent infringement. LG is without
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`1 LG repeats the headings set forth in the Complaint to simplify comparison of the Complaint and
`this Answer. In doing so, LG makes no admissions regarding the substance of the headings or any
`other allegations of the Complaint. Unless otherwise stated, to the extent that a particular heading
`can be construed as an allegation, LG specifically denies all such allegations.
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`knowledge or information sufficient to form a belief as to the truth of the remaining allegations in
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`Paragraph 1 of the Complaint and therefore denies those allegations.
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`2.
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`LG is without knowledge or information sufficient to form a belief as to the truth
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`of the allegations in Paragraph 2 of the Complaint and therefore denies those allegations.
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`3.
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`LG is without knowledge or information sufficient to form a belief as to the truth
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`of the allegations in Paragraph 3 of the Complaint and therefore denies those allegations.
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`4.
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`LG denies that it has committed any acts of patent infringement, whether knowing
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`or otherwise. LG is without knowledge or information sufficient to form a belief as to the truth of
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`the remaining allegations in Paragraph 4 of the Complaint and therefore denies those allegations.
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`5.
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`LG denies that it has committed any acts of patent infringement, whether knowing
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`or otherwise. Plaintiff’s remaining allegations in Paragraph 5 of the Complaint are vague and
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`indefinite, and LG is without knowledge or information sufficient to form a belief as to the truth
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`of those allegations, and therefore denies those allegations.
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`6.
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`LG is without knowledge or information sufficient to form a belief as to the truth
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`of the allegations contained in Paragraph 6 of the Complaint and therefore denies those allegations.
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`NATURE OF THE ACTIONS
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`7.
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`LG admits that Plaintiff’s Complaint purports to state a cause of action for patent
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`infringement under the patent laws of the United States, 35 U.S.C. § 271 et seq., but LG denies
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`that it has committed any acts of patent infringement.
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`PARTIES
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`8.
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`LG is without knowledge or information sufficient to form a belief as to the truth
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`of the allegations contained in Paragraph 8 of the Complaint and therefore denies those allegations.
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`9.
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`LGE admits that it is a corporation organized and existing under the laws of the
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`Republic of Korea with its principal place of business at LG Twin Towers, 128 Yeoui-daero
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`2
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`Yeongdeungpo-gu, Seoul, South Korea. LGE denies the remaining allegations in Paragraph 9 of
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`the Complaint.
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`10.
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`LGEUS admits that it is a Delaware corporation having a principal place of business
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`at 111 Sylvan Avenue, Englewood Cliffs, New Jersey 07632. LGEUS admits that it is a wholly
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`owned subsidiary of LGE. To the extent Paragraph 10 states legal conclusions, no response is
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`required. LG denies the remaining allegations in Paragraph 10 of the Complaint.
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`11.
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`Plaintiff’s allegations in Paragraph 11 of the Complaint are vague and indefinite,
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`and LG is without knowledge or information sufficient to form a belief as to the truth of the
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`allegations and therefore denies those allegations.
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`JURISDICTION AND VENUE
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`12.
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`LG admits that this Court has subject matter jurisdiction over actions for alleged
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`patent infringement arising under 35 U.S.C. § 271 et seq. pursuant to 28 U.S.C. §§ 1331 and
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`1338(a), but LG denies that it has committed any acts of patent infringement.
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`13.
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`LGEUS admits that it has sold and offered for sale in the United States, and
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`imported into the United States, certain smartphones, laptops, and tablets. LG admits that, in the
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`Spacetime3D case, LG stated that it “d[id] not contest that the Court ha[d] personal jurisdiction
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`over LGE Inc. or LGEUS for the purposes of th[at] particular action only, but d[id] not waive the
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`right to contest personal jurisdiction in any other case or action in this District.” No 2:22-cv-
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`00049-RWS, Dkt. 19 (LG’s June 20, 2022 Answer and Affirmative Defenses), ¶ 8. LG denies that
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`it has committed acts of patent infringement, in this District, the State of Texas, or elsewhere.
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`Paragraph 13 of the Complaint further contains legal conclusions to which no response is required.
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`To the extent a response is required, LG denies the allegations.
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`14.
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`Paragraph 14 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, LG denies the allegations.
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`3
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`15.
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`Venue in the Eastern District of Texas is not convenient under 28 U.S.C. § 1404.
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`LGE admits that it is organized under the laws of the Republic of Korea. The remaining allegations
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`in Paragraph 15 of the Complaint contain legal conclusions to which no response is required. To
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`the extent a response is required, LG denies the allegations.
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`16.
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`Paragraph 16 of the Complaint contains legal conclusions to which no response is
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`required. LG is without knowledge or information sufficient to form a belief as to the truth of the
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`remaining allegations and therefore denies the allegations.
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`COUNT 1 – [ALLEGED] INFRINGEMENT OF U.S. PATENT NO. 6,856,760
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`17.
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`18.
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`LG incorporates by reference paragraphs 1–16 as if fully set forth herein.
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`LG admits that, on its face, U.S. Patent No. 6,856,760 (“the ’760 patent”) is titled
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`“RECORDING MEDIUM” and reads “Date of Patent: *Feb. 15, 2005.” LG admits that Exhibit 1
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`to the Complaint is a purported copy of the ’760 patent. LG is without knowledge or information
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`sufficient to form a belief as to the truth of the remaining allegations in Paragraph 18 of the
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`Complaint and therefore denies those allegations.
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`19.
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`Paragraph 19 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, LG is without knowledge or information sufficient
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`to form a belief as to the truth of the allegations and therefore denies the allegations.
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`20.
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`Paragraph 20 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, LG is without knowledge or information sufficient
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`to form a belief as to the truth of the allegations and therefore denies the allegations.
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`21.
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`Plaintiff’s allegations in Paragraph 21 of the Complaint are vague and indefinite,
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`and LG is without knowledge or information sufficient to form a belief as to the truth of the
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`allegations and therefore denies the allegations.
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`4
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`22.
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`LG denies that it has committed any acts of patent infringement. Paragraph 22 of
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`the Complaint contains legal conclusions to which no response is required. To the extent a
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`response is required, the allegations are vague and indefinite, and LG is without knowledge or
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`information sufficient to form a belief as to the truth of the allegations and therefore denies the
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`allegations.
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`23.
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`Paragraph 23 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, the allegations are vague and indefinite, and LG
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`denies the allegations.
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`24.
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`Paragraph 24 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, the allegations are vague and indefinite, and LG
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`denies the allegations.
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`25.
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`LG denies that it has committed any acts of patent infringement. Paragraph 25 of
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`the Complaint contains legal conclusions to which no response is required. To the extent a
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`response is required, the allegations are vague and indefinite, and LG denies the allegations.
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`26.
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`LG denies that it has committed any acts of patent infringement or that it has
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`induced or contributed to any acts of patent infringement. LG admits that a pdf bearing the title
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`“User Guide LG V60 ThinQ™ 5G UW LM-V600VM OS: Android™ 11” can be accessed (as of
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`April 23, 2024) at https://ss7.vzw.com/is/content/VerizonWireless/Catalog%20Assets/Devices/
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`LG/LG_V60_ThinQ/userguide/lg-v60-thinq-5g-lm-v600vmengug-user-manual-en-
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`03132020.pdf. LG further admits that a webpage bearing the title “Manuals & Documents” can
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`be accessed (as of April 23, 2024) at https://www.lg.com/us/support/manuals-documents. LG
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`further answers that this pdf and webpage speak for themselves and no further response is required.
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`Paragraph 26 of the Complaint further contains legal conclusions to which no response is required.
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`5
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`To the extent a response is required, the allegations are vague and indefinite, and LG denies the
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`allegations.
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`27.
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`LG denies that it has committed any acts of patent infringement or that it has
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`induced or contributed to any acts of patent infringement. Paragraph 27 of the Complaint contains
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`legal conclusions to which no response is required. To the extent a response is required, the
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`allegations are vague and indefinite, and LG denies the allegations.
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`28.
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`LG denies that it has committed any acts of patent infringement or that it has
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`induced or contributed to any acts of patent infringement. Paragraph 28 of the Complaint contains
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`legal conclusions to which no response is required. To the extent a response is required, the
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`allegations are vague and indefinite, and LG denies the allegations.
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`29.
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`LG denies that it has committed any acts of patent infringement or that it has
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`induced or contributed to any acts of patent infringement. LG admits that a document purporting
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`to be correspondence bearing the names “Mr. Hwi jae Cho” and “Tatsuya Yamamoto” and the
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`date “July 19, 2021” was attached as Exhibit 2 to the Complaint. LG further answers that this
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`document speaks for itself and no further response is required. Paragraph 29 of the Complaint
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`further contains legal conclusions to which no response is required. To the extent a further
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`response is required, the allegations are vague and indefinite, and LG denies the allegations.
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`30.
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`LG denies that it has committed any acts of patent infringement. Paragraph 30 of
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`the Complaint contains legal conclusions to which no response is required. To the extent a
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`response is required, LG denies the allegations.
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`31.
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`LG denies the allegations in Paragraph 31 of the Complaint.
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`COUNT 2 – [ALLEGED] INFRINGEMENT OF U.S. PATENT NO. 6,973,334
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`32.
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`LG incorporates by reference paragraphs 1–31 as if fully set forth herein.
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`6
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`33.
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`LG admits that, on its face, U.S. Patent No. 6,973,334 (“the ’334 patent”) is titled
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`“CELLULAR TELEPHONE” and reads “Date of Patent: Dec. 6, 2005.” LG admits that Exhibit 3
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`to the Complaint is a purported copy of the ’334 patent. LG is without knowledge or information
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`sufficient to form a belief as to the truth of the remaining allegations in Paragraph 33 of the
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`Complaint and therefore denies those allegations.
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`34.
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`Paragraph 34 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, LG is without knowledge or information sufficient
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`to form a belief as to the truth of the allegations and therefore denies the allegations.
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`35.
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`Paragraph 35 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, the allegations are vague and indefinite, and LG is
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`without knowledge or information sufficient to form a belief as to the truth of the allegations and
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`therefore denies the allegations.
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`36.
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`LG denies that it has committed any acts of patent infringement. Paragraph 36 of
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`the Complaint contains legal conclusions to which no response is required. To the extent a
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`response is required, the allegations are vague and indefinite, and LG is without knowledge or
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`information sufficient to form a belief as to the truth of the allegations and therefore denies the
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`allegations.
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`37.
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`Paragraph 37 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, the allegations are vague and indefinite, and LG
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`denies the allegations.
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`38.
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`Paragraph 38 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, the allegations are vague and indefinite, and LG
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`denies the allegations.
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`7
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`
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`39.
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`LG admits that a webpage bearing the title “UMTS Power Control” can be accessed
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`(as of April 23, 2024) at https://www.umtsworld.com/technology/power.htm. LG further answers
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`that this webpage speaks for itself and no further response is required. Paragraph 39 of the
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`Complaint further contains legal conclusions to which no response is required. To the extent a
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`response is required, the allegations are vague and indefinite, and LG denies the allegations.
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`40.
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`Paragraph 40 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, the allegations are vague and indefinite, and LG
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`denies the allegations.
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`41.
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`Paragraph 41 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, the allegations are vague and indefinite, and LG
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`denies the allegations.
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`42.
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`Paragraph 42 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, the allegations are vague and indefinite, and LG
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`denies the allegations.
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`43.
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`LG refers to, and incorporates by reference, its response in ¶ 39, supra, regarding
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`https://www.umtsworld.com/technology/power.htm. Paragraph 43 of the Complaint further
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`contains legal conclusions to which no response is required. To the extent a response is required,
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`the allegations are vague and indefinite, and LG denies the allegations.
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`44.
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`LG admits that a webpage containing paragraphs bearing the titles “Power
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`Amplifier Modules” and “Power trackers” can be accessed (as of April 23, 2024) at
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`https://www.qualcomm.com/products/technology/modems/rf. LG further admits that a webpage
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`bearing the title “Snapdragon 865 5G Mobile Platform” can be accessed (as of April 23, 2024) at
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`https://www.qualcomm.com/products/mobile/snapdragon/smartphones/snapdragon-8-series-
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`8
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`
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`mobile-platforms/snapdragon-865-5g-mobile-platform. LG further answers that these webpages
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`speak for themselves and no further response is required. Paragraph 44 of the Complaint further
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`contains legal conclusions to which no response is required. To the extent a response is required,
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`the allegations are vague and indefinite, and LG denies the allegations.
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`45.
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`LG denies that it has committed any acts of patent infringement. Paragraph 45 of
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`the Complaint contains legal conclusions to which no response is required. To the extent a
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`response is required, the allegations are vague and indefinite, and LG denies the allegations.
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`46.
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`LG denies that it has committed any acts of patent infringement or that it has
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`induced or contributed to any acts of patent infringement. LG refers to, and incorporates by
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`reference, its responses in ¶ 26, supra, regarding Plaintiff’s website allegations. Paragraph 46 of
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`the Complaint further contains legal conclusions to which no response is required. To the extent
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`a response is required, the allegations are vague and indefinite, and LG denies the allegations.
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`47.
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`LG denies that it has committed any acts of patent infringement or that it has
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`induced or contributed to any acts of patent infringement. Paragraph 47 of the Complaint contains
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`legal conclusions to which no response is required. To the extent a response is required, the
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`allegations are vague and indefinite, and LG denies the allegations.
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`48.
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`LG denies that it has committed any acts of patent infringement or that it has
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`induced or contributed to any acts of patent infringement. Paragraph 48 of the Complaint contains
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`legal conclusions to which no response is required. To the extent a response is required, the
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`allegations are vague and indefinite, and LG denies the allegations.
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`49.
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`LG denies that it has committed any acts of patent infringement or that it has
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`induced or contributed to any acts of patent infringement. LG refers to, and incorporates by
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`reference, its response in ¶ 29, supra, regarding Exhibit 2. Paragraph 49 of the Complaint further
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`9
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`contains legal conclusions to which no response is required. To the extent a further response is
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`required, the allegations are vague and indefinite, and LG denies the allegations.
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`50.
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`LG denies that it has committed any acts of patent infringement. Paragraph 50 of
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`the Complaint contains legal conclusions to which no response is required. To the extent a
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`response is required, LG denies the allegations.
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`51.
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`LG denies the allegations in Paragraph 51 of the Complaint.
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`COUNT 3 – [ALLEGED] INFRINGEMENT OF U.S. PATENT NO. 7,199,821
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`52.
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`53.
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`LG incorporates by reference paragraphs 1–51 as if fully set forth herein.
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`LG admits that, on its face, U.S. Patent No. 7,199,821 (“the ’821 patent”) is titled
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`“IMAGING APPARATUS AND METHOD FOR CONTROLLING WHITE BALANCE” and
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`reads “Date of Patent: Apr. 3, 2007.” LG admits that Exhibit 4 to the Complaint is a purported
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`copy of the ’821 patent. LG is without knowledge or information sufficient to form a belief as to
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`the truth of the remaining allegations in Paragraph 53 of the Complaint and therefore denies those
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`allegations.
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`54.
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`Paragraph 54 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, LG is without knowledge or information sufficient
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`to form a belief as to the truth of the allegations and therefore denies the allegations.
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`55.
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`Plaintiff’s allegations in Paragraph 55 of the Complaint are vague and indefinite,
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`and LG is without knowledge or information sufficient to form a belief as to the truth of the
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`allegations and therefore denies the allegations.
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`56.
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`Plaintiff’s allegations in Paragraph 56 of the Complaint are vague and indefinite,
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`and LG is without knowledge or information sufficient to form a belief as to the truth of the
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`allegations and therefore denies the allegations.
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`57.
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`Paragraph 57 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, the allegations are vague and indefinite, and LG is
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`without knowledge or information sufficient to form a belief as to the truth of the allegations and
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`therefore denies the allegations.
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`58.
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`LG denies that it has committed any acts of patent infringement. Paragraph 58 of
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`the Complaint contains legal conclusions to which no response is required. To the extent a
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`response is required, the allegations are vague and indefinite, and LG is without knowledge or
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`information sufficient to form a belief as to the truth of the allegations and therefore denies the
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`allegations.
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`59.
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`Paragraph 59 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, the allegations are vague and indefinite, and LG
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`denies the allegations.
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`60.
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`LG denies that it has committed any acts of patent infringement. Paragraph 60 of
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`the Complaint contains legal conclusions to which no response is required. To the extent a
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`response is required, the allegations are vague and indefinite, and LG denies the allegations.
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`61.
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`LG denies that it has committed any acts of patent infringement. Paragraph 61 of
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`the Complaint contains legal conclusions to which no response is required. To the extent a
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`response is required, the allegations are vague and indefinite, and LG denies the allegations.
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`62.
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`LG denies that it has committed any acts of patent infringement or that it has
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`induced or contributed to any acts of patent infringement. LG refers to, and incorporates by
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`reference, its response in ¶ 26, supra, regarding Plaintiff’s website allegations. Paragraph 62 of
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`the Complaint further contains legal conclusions to which no response is required. To the extent
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`a response is required, the allegations are vague and indefinite, and LG denies the allegations.
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`63.
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`LG denies that it has committed any acts of patent infringement or that it has
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`induced or contributed to any acts of patent infringement. Paragraph 63 of the Complaint contains
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`legal conclusions to which no response is required. To the extent a response is required, the
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`allegations are vague and indefinite, and LG denies the allegations.
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`64.
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`LG denies that it has committed any acts of patent infringement or that it has
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`induced or contributed to any acts of patent infringement. Paragraph 64 of the Complaint contains
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`legal conclusions to which no response is required. To the extent a response is required, the
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`allegations are vague and indefinite, and LG denies the allegations.
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`65.
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`LG denies that it has committed any acts of patent infringement or that it has
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`induced or contributed to any acts of patent infringement. Paragraph 65 of the Complaint contains
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`legal conclusions to which no response is required. To the extent a response is required, the
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`allegations are vague and indefinite, and LG denies the allegations.
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`66.
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`LG denies that it has committed any acts of patent infringement or that it has
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`induced or contributed to any acts of patent infringement. LG refers to, and incorporates by
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`reference, its response in ¶ 29, supra, regarding Exhibit 2. Paragraph 66 of the Complaint further
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`contains legal conclusions to which no response is required. To the extent a response is required,
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`the allegations are vague and indefinite, and LG denies the allegations.
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`67.
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`LG denies that it has committed any acts of patent infringement or that it has
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`induced or contributed to any acts of patent infringement. Paragraph 67 of the Complaint contains
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`legal conclusions to which no response is required. To the extent a response is required, the
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`allegations are vague and indefinite, and LG denies the allegations.
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`68.
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`LG denies the allegations in Paragraph 68 of the Complaint.
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`COUNT 4 – [ALLEGED] INFRINGEMENT OF U.S. PATENT NO. 10,244,284
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`69.
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`LG incorporates by reference paragraphs 1–68 as if fully set forth herein.
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`70.
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`LG admits that, on its face, U.S. Patent No. 10,244,284 (“the ’284 patent”) is titled
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`“DISPLAY APPARATUS AND VIDEO PROCESSING APPARATUS” and reads “Date of
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`Patent: Mar. 26, 2019.” LG admits that Exhibit 5 to the Complaint is a purported copy of the ’284
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`patent. LG is without knowledge or information sufficient to form a belief as to the truth of the
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`remaining allegations in Paragraph 70 of the Complaint and therefore denies those allegations.
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`71.
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`Paragraph 71 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, LG is without knowledge or information sufficient
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`to form a belief as to the truth of the allegations and therefore denies the allegations.
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`72.
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`Plaintiff’s allegations in Paragraph 72 of the Complaint are vague and indefinite,
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`and LG is without knowledge or information sufficient to form a belief as to the truth of the
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`allegations and therefore denies those allegations.
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`73.
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`Plaintiff’s allegations in Paragraph 73 of the Complaint are vague and indefinite,
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`and LG is without knowledge or information sufficient to form a belief as to the truth of the
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`allegations and therefore denies those allegations.
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`74.
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`Paragraph 74 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, the allegations are vague and indefinite, and LG
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`denies the allegations.
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`75.
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`LG denies that it has committed any acts of patent infringement. Paragraph 75 of
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`the Complaint contains legal conclusions to which no response is required. To the extent a
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`response is required, the allegations are vague and indefinite, and LG is without knowledge or
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`information sufficient to form a belief as to the truth of the allegations and therefore denies the
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`allegations.
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`76.
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`Paragraph 76 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, the allegations are vague and indefinite, and LG
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`denies the allegations.
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`77.
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`Paragraph 77 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, the allegations are vague and indefinite, and LG
`
`denies the allegations.
`
`78.
`
`Paragraph 78 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, the allegations are vague and indefinite, and LG
`
`denies the allegations.
`
`79.
`
`Paragraph 79 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, the allegations are vague and indefinite, and LG
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`denies the allegations.
`
`80.
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`Paragraph 80 of the Complaint contains legal conclusions to which no response is
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`required. To the extent a response is required, the allegations are vague and indefinite, and LG
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`denies the allegations.
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`81.
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`LG denies that it has committed any acts of patent infringement. Paragraph 81 of
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`the Complaint contains legal conclusions to which no response is required. To the extent a
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`response is required, the allegations are vague and indefinite, and LG denies the allegations.
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`82.
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`LG denies that it has committed any acts of patent infringement or that it has
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`induced or contributed to any acts of patent infringement. LG refers to, and incorporates by
`
`reference, its response in ¶ 26, supra, regarding Plaintiff’s website allegations. Paragraph 82 of
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`the Complaint further contains legal conclusions to which no response is required. To the extent
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`a response is required, the allegations are vague and indefinite, and LG denies the allegations.
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`14
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`Case 5:23-cv-00152-RWS Document 13 Filed 04/23/24 Page 15 of 36 PageID #: 337
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`
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`83.
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`LG denies that it has committed any acts of patent infringement or that it has
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`induced or contributed to any acts of patent infringement. Paragraph 83 of the Complaint further
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`contains legal conclusions to which no response is required. To the extent a response is required,
`
`the allegations are vague and indefinite, and LG denies the allegations.
`
`84.
`
`LG denies that it has committed any acts of patent infringement or that it has
`
`induced or contributed to any acts of patent infringement. Paragraph 84 of the Complaint contains
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`legal conclusions to which no response is required. To the extent a response is required, the
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`allegations are vague and indefinite, and LG denies the allegations.
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`85.
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`LG denies that it has committed any acts of patent infringement or that it has
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`induced or contributed to any acts of patent infringement. Paragraph 85 of the Complaint contains
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`legal conclusions to which no response is required. To the extent a response is required, the
`
`allegations are vague and indefinite, and LG denies the allegations.
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`86.
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`LG denies that it has committed any acts of patent infringement or that it has
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`induced or contributed to any acts of patent infringement. LG refers to, and incorporates by
`
`reference, its response in ¶ 29, supra, regarding Exhibit 2. Paragraph 86 of the Complaint further
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`contains legal conclusions to which no response is required. To the extent a further response is
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`required, the allegations are vague and indefinite, and LG denies the allegations.
`
`87.
`
`LG denies that it has committed any acts of patent infringement or that it has
`
`induced or contributed to any acts of patent infringement. Paragraph 87 of the Complaint contains
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`legal conclusions to which no response is required. To the extent a response is required, the
`
`allegations are vague and indefinite, and LG denies the allegations.
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`88.
`
`LG denies the allegations in Paragraph 88 of the Complaint.
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`COUNT 5 – [ALLEGED] INFRINGEMENT OF U.S. PATENT NO. 8,339,493
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`89.
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`LG incorporates by reference paragraphs 1–88 as if fully set forth herein.
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`15
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`Case 5:23-cv-00152-RWS Document 13 Filed 04/23/24 Page 16 of 36 PageID #: 338
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`90.
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`LG admits that, on its face, U.S. Patent No. 8,339,493 (“the ’493 patent”) is titled
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`“ELECTRIC CAMERA” and reads “Date of Patent: *Dec. 25, 2012.” LG admits that Exhibit 6
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`to the Complaint is a purported copy of the ’493 patent. LG is without knowledge or information
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`sufficient to form a belief as to the truth of the remaining allegations in Paragraph 90 of the
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`Complaint and therefore denies those allegations.
`
`91.
`
`Paragraph 91 of the Complaint contains legal conclusions to which no response is
`
`required. To the extent a response is required, LG is without knowledge or information sufficient
`
`to form a belief as to the truth of the allegations and therefore denies the allegations.
`
`92.
`
`Paragraph 92 of the Complaint contains legal conclusions to which no response is
`
`required. To the extent a response is required, LG is without knowledge or information sufficient
`
`to form a belief as to the truth of the allegations and therefore denies the allegations.
`
`93.
`
`Plaintiff’s allegations in Paragraph 93 of the Complaint are vague and indefinite,
`
`and LG is without knowledge or information sufficient to form a belief as to the truth of the
`
`allegations and therefore denies the allegations.
`
`94.
`
`LG denies that it has committed any acts of patent infringement. Paragraph 94 of
`
`the Complaint contains legal conclusions to which no response is required. To the extent a
`
`response is required, the allegations are vague and indefinite, and LG is without knowledge or
`
`information sufficient to form a belief as to the truth of the allegations and therefore denies the
`
`allegations.
`
`95.
`
`Paragraph 95 of the Complaint contains legal conclusions to which no response is
`
`required. To the extent a response is required, the allegations are vague and indefinite, and LG
`
`denies the allegations.
`
`16
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`Case 5:23-cv-00152-RWS Document 13 Filed 04/23/24 Page 17 of 36 PageID #: 339
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`
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`96.
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`Paragraph 96 of the Complaint contains legal conclusions to which no response is
`
`required. To the extent a response is required, the allegations are vague and indefinite, and LG
`
`denies the allegations.
`
`97.
`
`LG admi