Case 6:21-cv-00520-ADA Document 10 Filed 09/29/21 Page 1 of 39
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`PARKERVISION, INC.,
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`Plaintiff,
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`v.
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`LG ELECTRONICS, INC.
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`Defendant.
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`Case No. 6:21-cv-00520
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`JURY TRIAL DEMANDED
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`ANSWER AND DEFENSES TO COMPLAINT FOR PATENT INFRINGEMENT
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`Defendant LG Electronics Inc. (“LG”), by and through its undersigned attorneys, hereby
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`responds to the Complaint For Patent Infringement (“Complaint”) of Plaintiff ParkerVision, Inc.
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`(“ParkerVision”), with the following Answer and Defenses. LG’s responses are made only on
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`behalf of LG Electronics Inc., the named defendant in this action.
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`GENERAL DENIAL
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`Unless as hereinafter expressly admitted, qualified, or otherwise admitted, LG
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`specifically denies each and every allegation, statement, matter, and thing contained in the
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`Complaint. LG further denies that ParkerVision is entitled to the requested relief or to any relief
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`against LG.
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`RESPONSE TO SPECIFIC ALLEGATIONS
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`LG hereby responds to the numbered paragraphs of the Complaint with the following
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`correspondingly numbered responses:
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`Case 6:21-cv-00520-ADA Document 10 Filed 09/29/21 Page 2 of 39
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`NATURE OF THE ACTION1
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`1.
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`This paragraph states legal conclusions to which no response is required. To the
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`extent a further response is required, LG admits that ParkerVision alleges in its Complaint that
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`this action arises under the patent laws of the United States, 35 U.S.C. §§ 1 et seq. LG denies
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`any wrongdoing in violation of, or liability under, any such laws. Except as admitted herein, LG
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`denies each and every allegation in Paragraph 1 of the Complaint.
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`PARTIES
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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 them.
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`3.
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`LG admits that it is a foreign corporation organized under the laws of the
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`Republic of South Korea. LG admits that its principal place of business is at LG Twin Tower
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`128, Yeoui-daero, Yeongdeungpo-gu, Seoul, Korea. Except as admitted herein, LG denies each
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`and every allegation in Paragraph 3 of the Complaint.
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`4.
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`LG denies each and every allegation in Paragraph 4 of the Complaint.
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`JURISDICTION AND VENUE
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`5.
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`LG admits that this action purports to arise under the patent laws of the United
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`States. To the extent that Paragraph 5 states a legal conclusion, no response is required. LG
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`admits that this Court has subject matter jurisdiction over actions arising under the patent laws of
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`the United States pursuant to 28 U.S.C. §§ 1331 and 1338. Except as admitted herein, LG denies
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`each and every allegation in Paragraph 5 of the Complaint.
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`6.
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`To the extent that Paragraph 6 states a legal conclusion, no response is required.
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`LG otherwise denies the allegations of Paragraph 6 of the Complaint.
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`1 For the purposes of this pleading, LG uses the headings in ParkerVision’s Complaint. To the
`extent any response is required, LG denies any allegations contained in those headings.
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`7.
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`To the extent that Paragraph 7 states a legal conclusion, no response is required.
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`LG otherwise denies the allegations of Paragraph 7 of the Complaint.
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`8.
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`To the extent that Paragraph 8 states a legal conclusion, no response is required.
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`LG otherwise denies the allegations of Paragraph 8 of the Complaint.
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`9.
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`To the extent that Paragraph 9 states a legal conclusion, no response is required.
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`LG otherwise denies the allegations of Paragraph 9 of the Complaint.
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`10.
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`To the extent that Paragraph 10 states a legal conclusion, no response is required.
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`To the extent that a response is required, LG admits that it is a foreign corporation but denies that
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`venue is appropriate or convenient in this Court. LG otherwise denies the allegations of
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`Paragraph 10 of the Complaint.
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`BACKGROUND
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`11.
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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 11 of the Complaint and, therefore, denies them.
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`12.
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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 12 of the Complaint and, therefore, denies them.
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`13.
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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 13 of the Complaint and, therefore, denies them.
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`14.
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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 14 of the Complaint and, therefore, denies them.
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`15.
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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 15 of the Complaint and, therefore, denies them.
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`16.
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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 16 of the Complaint and, therefore, denies them.
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`Case 6:21-cv-00520-ADA Document 10 Filed 09/29/21 Page 4 of 39
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`17.
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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 17 of the Complaint and, therefore, denies them.
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`LG
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`18.
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`LG admits it is a company headquartered in Seoul, South Korea. LG otherwise
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`denies the allegations of Paragraph 18 of the Complaint.
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`19.
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`To the extent that Paragraph 19 states a legal conclusion, no response is required.
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`To the extent that a response is required, LG denies that it has made, used, sold, offered for sale
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`and/or imported televisions in/into the United States. LG otherwise denies the allegations of
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`Paragraph 19 of the Complaint.
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`20.
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`LG denies that it has made, used, sold, offered for sale and/or imported televisions
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`in/into the United States. LG admits that televisions bearing “LG” branding can be purchased at
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`certain third-party retailers in the United States. LG otherwise denies the allegations of
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`Paragraph 20 of the Complaint.
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`21.
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`LG denies that it has made, used, sold, offered for sale and/or imported televisions
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`in/into the United States. LG is without knowledge or information sufficient to form a belief as
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`to the truth of the allegations in Paragraph 21 of the Complaint and, therefore, denies them.
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`22.
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`LG denies that it has made, used, sold, offered for sale and/or imported televisions
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`in/into the United States. LG is without knowledge or information sufficient to form a belief as
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`to the truth of the allegations in Paragraph 22 of the Complaint and, therefore, denies them.
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`23.
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`LG denies that it has made, used, sold, offered for sale and/or imported televisions
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`in/into the United States. LG admits that certain televisions include third-party modules
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`containing Wi-Fi chips. LG also admits that certain televisions include MediaTek MT7612UN
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`or MT7662TU chips or Realtek RTL8812BU chips that are provided by third parties. LG also
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`admits that wireless connectivity for certain televisions is provided by wireless chips
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`Case 6:21-cv-00520-ADA Document 10 Filed 09/29/21 Page 5 of 39
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`manufactured by third parties. To the extent any other response to the allegations in Paragraph
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`23 is required, LG denies such allegations.
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`24.
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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 24 of the Complaint, including any actions taken by entities other
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`than LG the named defendant in this action, and, therefore, denies them. LG admits that the first
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`image in Paragraph 24, on page 6 of the Complaint, purports to be an excerpt of a User Manual
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`and that the image otherwise speaks for itself. LG also admits that the second image in
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`Paragraph 24, on page 7 of the complaint, depicts various electronic components and that the
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`image otherwise speaks for itself. To the extent any other response to the allegations in
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`Paragraph 24 is required, LG denies such allegations.
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`25.
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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 25 of the Complaint, including any actions taken by entities other
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`than LG the named defendant in this action, and, therefore, denies them. LG admits that the first
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`image in Paragraph 25, on the top of page 8 of the Complaint, purports to be an excerpt of a
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`specification document and that the image otherwise speaks for itself. LG also admits that the
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`second image in Paragraph 25, on the bottom of page 8 of the complaint, depicts various
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`electronic components and otherwise speaks for itself. To the extent any other response to the
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`allegations in Paragraph 25 is required, LG denies such allegations.
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`26.
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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 26 of the Complaint, including any actions taken by entities other
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`than LG the named defendant in this action, and, therefore, denies them. LG admits that the first
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`image in Paragraph 26, on the top of page 9 of the Complaint, purports to be an excerpt of a
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`specification document and that the image otherwise speaks for itself. LG also admits that the
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`Case 6:21-cv-00520-ADA Document 10 Filed 09/29/21 Page 6 of 39
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`second image in Paragraph 26, on the bottom of page 9 of the complaint, depicts various
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`electronic components and otherwise speaks for itself. To the extent any other response to the
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`allegations in Paragraph 26 is required, LG denies such allegations.
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`27.
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`LG admits that the 65UK6200PUA, 55UK6200PUA, 49UK6200PUA,
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`43UK6200PUA, 65UK6090PUA, 60UK6090PUA, 55UK6090PUA, 50UK6090PUA,
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`75UK6190PUB, and 70UK6190PUB models contain the LGSWFAC71 module and the
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`MediaTek MT7612UN chip. LG denies that it has made, used, sold, offered for sale and/or
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`imported televisions in/into the United States, and denies the remaining allegations in Paragraph
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`27 of the Complaint.
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`28.
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`LG admits that the 49LK5700PUA, 49LK5700BUA, 43LK5700PUA, and
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`43LK5700BUA models contain the LGSWFAC81 module and the Realtek RTL8812BU chip.
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`LG denies that it has made, used, sold, offered for sale and/or imported televisions in/into the
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`United States, and denies the remaining allegations in Paragraph 28 of the Complaint.
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`29.
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`LG admits that the 65SK9500PUA, 55SK9500PUA, 65SK9550PUA,
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`65SK9000PUA, 55SK9000PUA, 65SK8550PUA, 55SK8550PUA, 75SK8070PUA,
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`75SK8050PUA, 75SK8070AUB, 65SK8000AUB, 55SK8000AUB, 65SK8000PUA,
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`55SK8000PUA, 49SK8000PUA, 65SK8050PUA, 55SK8050PUA, 49SK8050PUA,
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`65UK7700AUB, 65UK7700PUD, 55UK7700AUB, 55UK7700PUD, 49UK7700AUB,
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`49UK7700PUD, 65UK7500PUA, 55UK7500PUA, 49UK7500PUA, 86UK6570PUB,
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`75UK6570PUB, 75UK6570PUA, 86UK6570AUA, 75UK6570AUA, 70UK6570PUB,
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`70UK6550PUA, 70UK6570AUB, 65UK6500AUA, 55UK6500AUA, 50UK6500AUA,
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`43UK6500AUA, 65UK6550PUB ,55UK6550PUB, 50UK6550PUB, 43UK6550PUB,
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`65UK6300PUE, 55UK6300PUE, 50UK6300PUE, 49UK6300PUE, 43UK6300PUE,
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`Case 6:21-cv-00520-ADA Document 10 Filed 09/29/21 Page 7 of 39
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`65UK6300BUB, 65UK6350PUC, 55UK6300BUB, 55UK6350PUC, 50UK6300BUB,
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`49UK6300BUB, 49UK6350PUC, 43UK6300BUB, 43UK6350PUC, 50UK6350PUC,
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`86UK7570PUB, 49LK5750PUA, OLED77C8PUA, OLED65B8PUA, OLED65B8SUC,
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`OLED65C8PUA, OLED65C8AUA, OLED65E8PUA, OLED55B8PUA, OLED55B8SUC,
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`OLED55C8PUA, OLED55C8AUA, and OLED55E8PUA models contain the LGSBWAC72
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`module and the MediaTek MT7662TU chip. LG denies that it has made, used, sold, offered for
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`sale and/or imported televisions in/into the United States, and denies the remaining allegations in
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`Paragraph 29 of the Complaint.
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`THE ASSERTED PATENTS
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`United States Patent No. 6,049,706
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`30.
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`LG admits that according to the United States Patent and Trademark Office’s
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`(“USPTO”) Patent Full-Text and Image Database, U.S. Patent No. 6,049,706 (the “’706 patent”)
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`states on its face that it is titled “Integrated Frequency Translation and Selectivity” and that it
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`issued on April 11, 2000. LG denies that the ’706 patent is a valid or duly and legally issued
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`patent. Except as admitted herein, LG denies each and every allegation in Paragraph 30 of the
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`Complaint.
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`31.
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`This paragraph states a legal conclusion to which no response is required. To the
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`extent a further response is required, LG denies that the ’706 patent is valid and enforceable. LG
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`denies the remaining allegations in Paragraph 31 of the Complaint.
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`32.
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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 32 of the Complaint and, therefore, denies them.
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`United States Patent No. 6,266,518
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`33.
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`LG admits that according to the USPTO’s Patent Full-Text and Image Database,
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`U.S. Patent No. 6,266,518 (the “’518 patent”) states on its face that it is titled “Method and
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`-7-
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`System for Down-Converting Electromagnetic Signals by Sampling and Integrating Over
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`Apertures” and that it issued on July 24, 2001. LG denies that the ’518 patent is a valid or duly
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`and legally issued patent. Except as admitted herein, LG denies each and every allegation in
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`Paragraph 33 of the Complaint.
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`34.
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`This paragraph states a legal conclusion to which no response is required. To the
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`extent a further response is required, LG denies that the ’518 patent is valid and enforceable. LG
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`denies the remaining allegations in Paragraph 34 of the Complaint.
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`35.
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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 35 of the Complaint and, therefore, denies them.
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`United States Patent No. 6,580,902
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`36.
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`LG admits that according to the USPTO’s Patent Full-Text and Image Database,
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`U.S. Patent No. 6,580,902 (the “’902 patent”) states on its face that it is titled “Frequency
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`Translation Using Optimized Switch Structures” and that it issued on June 17, 2003. LG denies
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`that the ’902 patent is a valid or duly and legally issued patent. Except as admitted herein, LG
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`denies each and every allegation in Paragraph 36 of the Complaint.
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`37.
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`This paragraph states a legal conclusion to which no response is required. To the
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`extent a further response is required, LG denies that the ’902 patent is valid and enforceable. LG
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`denies the remaining allegations in Paragraph 37 of the Complaint.
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`38.
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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 38 of the Complaint and, therefore, denies them.
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`United States Patent No. 7,110,444
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`39.
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`LG admits that according to the USPTO’s Patent Full-Text and Image Database,
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`U.S. Patent No. 7,110,444 (the “’444 patent”) states on its face that it is titled “Wireless Local
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`Area Network (WLAN) Using Universal Frequency Translation Technology Including Multi-
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`Phase Embodiments and Circuit Implementations” and that it issued on September 19, 2006. LG
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`denies that the ’444 patent is a valid or duly and legally issued patent. Except as admitted herein,
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`LG denies each and every allegation in Paragraph 39 of the Complaint.
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`40.
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`This paragraph states a legal conclusion to which no response is required. To the
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`extent a further response is required, LG denies that the ’444 patent is valid and enforceable. LG
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`denies the remaining allegations in Paragraph 40 of the Complaint.
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`41.
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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 41 of the Complaint and, therefore, denies them.
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`United States Patent No. 7,292,835
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`42.
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`LG admits that according to the USPTO’s Patent Full-Text and Image Database,
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`U.S. Patent No. 7,292,835 (the “’835 patent”) states on its face that it is titled “Wireless and
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`Wired Cable Modem Applications of Universal Frequency Translation Technology” and that it
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`issued on November 6, 2007. LG denies that the ’835 patent is a valid or duly and legally issued
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`patent. Except as admitted herein, LG denies each and every allegation in Paragraph 42 of the
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`Complaint.
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`43.
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`This paragraph states a legal conclusion to which no response is required. To the
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`extent a further response is required, LG denies that the ’835 patent is valid and enforceable. LG
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`denies the remaining allegations in Paragraph 43 of the Complaint.
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`44.
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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 44 of the Complaint and, therefore, denies them.
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`United States Patent No. 8,588,725
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`45.
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`LG admits that according to the USPTO’s Patent Full-Text and Image Database,
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`U.S. Patent No. 8,588,725 (the “’725 patent”) states on its face that it is titled “Apparatus,
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`System, and Method For Down Converting and Up-Converting Electromagnetic Signals” and
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`that it issued on November 19, 2013. LG denies that the ’725 patent is a valid or duly and
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`legally issued patent. Except as admitted herein, LG denies each and every allegation in
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`Paragraph 45 of the Complaint.
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`46.
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`This paragraph states a legal conclusion to which no response is required. To the
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`extent a further response is required, LG denies that the ’725 patent is valid and enforceable. LG
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`denies the remaining allegations in Paragraph 46 of the Complaint.
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`47.
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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 47 of the Complaint and, therefore, denies them.
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`United States Patent No. 8,660,513
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`48.
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`LG admits that according to the USPTO’s Patent Full-Text and Image Database,
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`U.S. Patent No. 8,660,513 (the “’513 patent”) states on its face that it is titled “Method and
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`System for Down-Converting an Electromagnetic Signal, and Transforms for Same, and
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`Aperture Relationships” and that it issued on February 25, 2014. LG denies that the ’513 patent
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`is a valid or duly and legally issued patent. Except as admitted herein, LG denies each and every
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`allegation in Paragraph 48 of the Complaint.
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`49.
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`This paragraph states a legal conclusion to which no response is required. To the
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`extent a further response is required, LG denies that the ’513 patent is valid and enforceable. LG
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`denies the remaining allegations in Paragraph 49 of the Complaint.
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`50.
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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 50 of the Complaint and, therefore, denies them.
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`United States Patent No. 9,118,528
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`51.
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`LG admits that according to the USPTO’s Patent Full-Text and Image Database,
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`U.S. Patent No. 9,118,528 (the “’528 patent”) states on its face that it is titled “Method and
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`System for Down-Converting an Electromagnetic Signal, and Transforms for Same, and
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`Aperture Relationships” and that it issued on August 25, 2015. LG denies that the ’528 patent is
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`a valid or duly and legally issued patent. Except as admitted herein, LG denies each and every
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`allegation in Paragraph 51 of the Complaint.
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`52.
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`This paragraph states a legal conclusion to which no response is required. To the
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`extent a further response is required, LG denies that the ’528 patent is valid and enforceable. LG
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`denies the remaining allegations in Paragraph 52 of the Complaint.
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`53.
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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 53 of the Complaint and, therefore, denies them.
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`United States Patent No. 9,246,736
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`54.
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`LG admits that according to the USPTO’s Patent Full-Text and Image Database,
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`U.S. Patent No. 9,246,736 (the “’736 patent”) states on its face that it is titled "Method and
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`System for Down-Converting an Electromagnetic Signal” and that it issued on January 26, 2016.
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`LG denies that the ’736 patent is a valid or duly and legally issued patent. Except as admitted
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`herein, LG denies each and every allegation in Paragraph 54 of the Complaint.
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`55.
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`This paragraph states a legal conclusion to which no response is required. To the
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`extent a further response is required, LG denies that the ’736 patent is valid and enforceable. LG
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`denies the remaining allegations in Paragraph 55 of the Complaint.
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`56.
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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 56 of the Complaint and, therefore, denies them.
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`United States Patent No. 9,444,673
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`57.
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`LG admits that according to the USPTO’s Patent Full-Text and Image Database,
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`U.S. Patent No. 9,444,673 (the “’673 patent”) states on its face that it is titled “Methods and
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`Systems for Down-Converting a Signal Using a Complementary Transistor Structure” and that it
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`issued on September 13, 2016. LG denies that the ’673 patent is a valid or duly and legally
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`issued patent. Except as admitted herein, LG denies each and every allegation in Paragraph 57
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`of the Complaint.
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`58.
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`This paragraph states a legal conclusion to which no response is required. To the
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`extent a further response is required, LG denies that the ’673 patent is valid and enforceable. LG
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`denies the remaining allegations in Paragraph 58 of the Complaint.
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`59.
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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 59 of the Complaint and, therefore, denies them.
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`CLAIMS FOR RELIEF
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`COUNT I – [Alleged] Infringement of United States Patent No. 6,049,706
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`60.
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`LG incorporates by reference its responses to the allegation contained in
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`Paragraphs 1 through 59 of the Complaint.
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`61.
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`Denied.
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`62.
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`Denied.
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`63.
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`Paragraph 63 merely restates language from the claims and specification of the
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`’706 patent and makes no effort to address the actual functioning of any accused product. LG
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`denies that it has made, used, sold, offered for sale and/or imported any accused product in/into
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`the United States. To the extent that the allegations of Paragraph 63 include terms that may be
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`subject to construction in this case, such allegations are legal conclusions for which no response
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`is necessary. LG denies infringement of any valid and enforceable claim of the ’706 patent. To
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`the extent any further response is required, LG denies each and every allegation in Paragraph 63
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`of the Complaint.
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`64.
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`Paragraph 64 merely restates language from the claims and specification of the
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`’706 patent and makes no effort to address the actual functioning of any accused product. To the
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`extent that the allegations of Paragraph 64 include terms that may be subject to construction in
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`Case 6:21-cv-00520-ADA Document 10 Filed 09/29/21 Page 13 of 39
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`this case, such allegations are legal conclusions for which no response is necessary. LG denies
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`infringement of any valid and enforceable claim of the ’706 patent. To the extent any further
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`response is required, LG denies each and every allegation in Paragraph 64 of the Complaint.
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`65.
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`Denied.
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`COUNT II – [Alleged] Infringement of United States Patent No. 6,266,518
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`66.
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`LG incorporates by reference its responses to the allegation contained in
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`Paragraphs 1 through 65 of the Complaint.
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`67.
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`Denied.
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`68.
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`Denied.
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`69.
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`Paragraph 69 merely restates language from the claims and specification of the
`
`’518 patent and makes no effort to address the actual functioning of any accused product. LG
`
`denies that it has made, used, sold, offered for sale and/or imported any accused product in/into
`
`the United States. To the extent that the allegations of Paragraph 69 include terms that may be
`
`subject to construction in this case, such allegations are legal conclusions for which no response
`
`is necessary. LG denies infringement of any valid and enforceable claim of the ’518 patent. To
`
`the extent any further response is required, LG denies each and every allegation in Paragraph 69
`
`of the Complaint.
`
`70.
`
`Paragraph 70 merely restates language from the claims and specification of the
`
`’518 patent and makes no effort to address the actual functioning of any accused product. To the
`
`extent that the allegations of Paragraph 70 include terms that may be subject to construction in
`
`this case, such allegations are legal conclusions for which no response is necessary. LG denies
`
`infringement of any valid and enforceable claim of the ’518 patent. To the extent any further
`
`response is required, LG denies each and every allegation in Paragraph 70 of the Complaint.
`
`
`
`
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`Case 6:21-cv-00520-ADA Document 10 Filed 09/29/21 Page 14 of 39
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`
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`71.
`
`Paragraph 71 merely restates language from the claims and specification of the
`
`’518 patent and makes no effort to address the actual functioning of any accused product. To the
`
`extent that the allegations of Paragraph 71 include terms that may be subject to construction in
`
`this case, such allegations are legal conclusions for which no response is necessary. LG denies
`
`infringement of any valid and enforceable claim of the ’518 patent. To the extent any further
`
`response is required, LG denies each and every allegation in Paragraph 71 of the Complaint.
`
`72.
`
`Paragraph 72 merely restates language from the claims and specification of the
`
`’518 patent and makes no effort to address the actual functioning of any accused product. To the
`
`extent that the allegations of Paragraph 72 include terms that may be subject to construction in
`
`this case, such allegations are legal conclusions for which no response is necessary. LG denies
`
`infringement of any valid and enforceable claim of the ’518 patent. To the extent any further
`
`response is required, LG denies each and every allegation in Paragraph 72 of the Complaint.
`
`73.
`
`Denied.
`
`COUNT III – [Alleged] Infringement of United States Patent No. 6,580,902
`
`74.
`
`LG incorporates by reference its responses to the allegation contained in
`
`Paragraphs 1 through 73 of the Complaint.
`
`75.
`
`Denied.
`
`76.
`
`Denied.
`
`77.
`
`Paragraph 77 merely restates language from the claims and specification of the
`
`’902 patent and makes no effort to address the actual functioning of any accused product. LG
`
`denies that it has made, used, sold, offered for sale and/or imported any accused product in/into
`
`the United States. To the extent that the allegations of Paragraph 77 include terms that may be
`
`subject to construction in this case, such allegations are legal conclusions for which no response
`
`is necessary. LG denies infringement of any valid and enforceable claim of the ’902 patent. To
`
`
`
`
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`Case 6:21-cv-00520-ADA Document 10 Filed 09/29/21 Page 15 of 39
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`
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`the extent any further response is required, LG denies each and every allegation in Paragraph 77
`
`of the Complaint.
`
`78.
`
`Paragraph 78 merely restates language from the claims and specification of the
`
`’902 patent and makes no effort to address the actual functioning of any accused product. LG
`
`denies that it has made, used, sold, offered for sale and/or imported any accused product in/into
`
`the United States. To the extent that the allegations of Paragraph 78 include terms that may be
`
`subject to construction in this case, such allegations are legal conclusions for which no response
`
`is necessary. LG denies infringement of any valid and enforceable claim of the ’902 patent. To
`
`the extent any further response is required, LG denies each and every allegation in Paragraph 78
`
`of the Complaint.
`
`79.
`
`Paragraph 79 merely restates language from the claims and specification of the
`
`’902 patent and makes no effort to address the actual functioning of any accused product. To the
`
`extent that the allegations of Paragraph 79 include terms that may be subject to construction in
`
`this case, such allegations are legal conclusions for which no response is necessary. LG denies
`
`infringement of any valid and enforceable claim of the ’902 patent. To the extent any further
`
`response is required, LG denies each and every allegation in Paragraph 79 of the Complaint.
`
`80.
`
`Paragraph 80 merely restates language from the claims and specification of the
`
`’902 patent and makes no effort to address the actual functioning of any accused product. LG
`
`denies that it has made, used, sold, offered for sale and/or imported any accused product in/into
`
`the United States. To the extent that the allegations of Paragraph 80 include terms that may be
`
`subject to construction in this case, such allegations are legal conclusions for which no response
`
`is necessary. LG denies infringement of any valid and enforceable claim of the ’902 patent. To
`
`
`
`
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`Case 6:21-cv-00520-ADA Document 10 Filed 09/29/21 Page 16 of 39
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`
`
`the extent any further response is required, LG denies each and every allegation in Paragraph 80
`
`of the Complaint.
`
`81.
`
`Denied.
`
`COUNT IV - [Alleged] Infringement of United States Patent No. 7,110,444
`
`82.
`
`LG incorporates by reference its responses to the allegation contained in
`
`Paragraphs 1 through 81 of the Complaint.
`
`83.
`
`Denied.
`
`84.
`
`Denied.
`
`85.
`
`Paragraph 85 merely restates language from the claims and specification of the
`
`’444 patent and makes no effort to address the actual functioning of any accused product. LG
`
`denies that it has made, used, sold, offered for sale and/or imported any accused product in/into
`
`the United States. To the extent that the allegations of Paragraph 85 include terms that may be
`
`subject to construction in this case, such allegations are legal conclusions for which no response
`
`is necessary. LG denies infringement of any valid and enforceable claim of the ’444 patent. To
`
`the extent any further response is required, LG denies each and every allegation in Paragraph 85
`
`of the Complaint.
`
`86.
`
`Paragraph 86 merely restates language from the claims and specification of the
`
`’444 patent and makes no effort to address the actual functioning of any accused product. To the
`
`extent that the allegations of Paragraph 86 include terms that may be subject to construction in
`
`this case, such allegations are legal conclusions for which no response is necessary. LG denies
`
`infringement of any valid and enforceable claim of the ’444 patent. To the extent any further
`
`response is required, LG denies each and every allegation in Paragraph 86 of the Complaint.
`
`87.
`
`Denied.
`
`
`
`
`-16-
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`

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`Case 6:21-cv-00520-ADA Document 10 Filed 09/29/21 Page 17 of 39
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`
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`COUNT V - [Alleged] Infringement of United States Patent No. 7,292,835
`
`88.
`
`LG incorporates by reference its responses to the allegation contained in
`
`Paragraphs 1 through 87 of the Complaint.
`
`89.
`
`Denied.
`
`90.
`
`Denied.
`
`91.
`
`LG admits that certain LG televisions may be connected to a wired and/or
`
`wireless network. LG is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegation that “LG Products enable uses to watch live TV and on demand
`
`programming from their cable service providers, such as Spectrum, over a wireless network” in
`
`Paragraph 91 of the Complaint and, therefore, denies them. The remaining allegations in
`
`Paragraph 91 seek legal conclusions to which no response is required. LG denies that it has
`
`made, used, sold, offered for sale and/or imported any accused product in/into the United States.
`
`To the extent any further response to the allegations in Paragraph 91 is required, LG denies such
`
`allegations.
`
`92.
`
`Paragraph 92 merely restates language from the claims and specification of the
`
`’835 patent and makes no effort to address the actual functioning of any accused product. LG
`
`denies that it has made, used, sold, offered for sale and/or imported any accused product in/into
`
`the United States. To the extent that the allegations of Paragraph 92 include terms that may be
`
`subject to construction in this case, such allegations are legal conclusions for which no response
`
`is necessary. LG denies infringement of any valid and enforceable claim of the ’835 patent. To
`
`the extent any further response is required, LG denies each and every allegation in Parag