Case 3:14-cv-00757-REP-DJN Document 50 Filed 01/26/15 Page 1 of 572 PageID# 1218
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`Richmond Division
`
`Plaintiff,
`
`
`
`SAMSUNG ELECTRONICS CO. LTD., et.
`al.,
`
`
`
`v.
`
`NVIDIA CORPORATION, et. al.
`
`
`
`
`Defendant.
`
`
`
`
`
`
`CIVIL ACTION NO. 3:14cv757-REP
`
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`DEFENDANT NVIDIA CORPORATION’S ANSWER TO AMENDED COMPLAINT
`
`Defendant NVIDIA Corporation (“NVIDIA” or “Defendant”), by and through its
`
`undersigned attorneys, hereby file this Answer to Plaintiffs Samsung Electronics Company, Ltd.
`
`(“SEC”) and Samsung Electronics America, Inc.’s (“SEA”) (collectively “Plaintiffs” or
`
`“Samsung”) First Amended Complaint. Defendant states as follows:
`
`THE PARTIES
`
`1.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`2.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`3.
`
`Defendant admits that it is a Delaware corporation with its principal place of
`
`business at 2701 San Tomas Expressway, Santa Clara, California 95050. Defendant further
`
`admits that it imports into the United States, offers for sale, sells and/or uses in the United States
`
`certain graphics processing units and/or systems-on-a-chip, and denies any remaining allegations
`
`in this paragraph.
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 50 Filed 01/26/15 Page 2 of 572 PageID# 1219
`
`4.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`5.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`SAMSUNG
`
`6.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`7.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`8.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`9.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`10.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`11.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`12.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`13.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`14.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`2
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 50 Filed 01/26/15 Page 3 of 572 PageID# 1220
`
`15.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`16.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`NVIDIA
`
`17.
`
`Defendant admits that it designs, develops, supplies, and sells graphics processing
`
`units and mobile system-on-chip products. The accuracy of the remaining allegations contained
`
`in this paragraph depends on context and the paragraph contains subjective assessments from
`
`Plaintiffs. Thus, Defendant lacks knowledge or information sufficient to form a belief as to the
`
`truth or falsity of the remaining allegations contained in this paragraph and therefore denies
`
`them.
`
`18.
`
`Defendant admits that it sells a device named the Shield Tablet. Defendant
`
`further admits that the Shield Tablet supports the Android operating system. Defendants are
`
`without knowledge or information sufficient to form a belief as to the truth of the remaining
`
`allegations set forth in this paragraph, and on that basis deny them.
`
`19.
`
`Defendant admits that it sells products and services through the United States,
`
`including in Virginia, and denies any remaining allegations in this paragraph.
`
`20.
`
`Defendant admits that it sells products nationwide, including in Virginia.
`
`Defendant further avers that the referenced document speaks for itself, and denies all other
`
`allegations in this paragraph.
`
`21.
`
`Defendant admits that it is registered as a foreign corporation with the
`
`Commonwealth of Virginia and may be served with process through its registered agent,
`
`Corporation Service Company, 1111 East Main Street, Richmond, VA 23219.
`
`VELOCITY
`
`3
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 50 Filed 01/26/15 Page 4 of 572 PageID# 1221
`
`22.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`23.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`24.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`25.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`26.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`27.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`28.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`29.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`30.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`31.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`JURISDICTION AND VENUE
`
`32.
`
`Defendant admits that this action purports to arise under the patent laws of the
`
`United States, Title 35 of the United States Code, but denies that this action has any merit or that
`
`4
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 50 Filed 01/26/15 Page 5 of 572 PageID# 1222
`
`Plaintiffs are entitled to the relief sought. Defendant also admits that this Court has subject
`
`matter jurisdiction, but denies the remaining allegations of this paragraph.
`
`33.
`
`34.
`
`35.
`
`Defendant denies the allegations in this paragraph.
`
`Defendant denies the allegations in this paragraph.
`
`Defendant denies the legal argument improperly included in this paragraph, and
`
`denies all remaining factual allegations.
`
`36.
`
`Defendant admits that it sells products nationwide, including in Virginia, and
`
`denies all other allegations in this paragraph.
`
`37.
`
`Defendant admits that it is registered as a foreign corporation with the
`
`Commonwealth of Virginia and may be served with process through its registered agent,
`
`Corporation Service Company, 1111 East Main Street, Richmond, VA 23219.
`
`38.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`39.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`40.
`
`Defendant denies the allegations in this paragraph.
`
`ACCUSED PRODUCTS
`
`41.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`42.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`43.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`44.
`
`Defendant denies the allegations in this paragraph.
`
`5
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 50 Filed 01/26/15 Page 6 of 572 PageID# 1223
`
`45.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`46.
`
`47.
`
`Defendant denies the allegations in this paragraph.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`48.
`
`The allegations in this paragraph contain subjective assessments from Plaintiffs
`
`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
`
`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
`
`49.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`50.
`
`The allegations in this paragraph contain subjective assessments from Plaintiffs
`
`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
`
`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
`
`51.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`52.
`
`The allegations in this paragraph contain subjective assessments from Plaintiffs
`
`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
`
`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
`
`53.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`54.
`
`The allegations in this paragraph contain subjective assessments from Plaintiffs
`
`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
`
`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
`
`6
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 50 Filed 01/26/15 Page 7 of 572 PageID# 1224
`
`55.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`56.
`
`The allegations in this paragraph contain subjective assessments from Plaintiffs
`
`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
`
`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
`
`57.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`58.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`59.
`
`The allegations in this paragraph contain subjective assessments from Plaintiffs
`
`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
`
`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
`
`60.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`61.
`
`The allegations in this paragraph contain subjective assessments from Plaintiffs
`
`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
`
`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
`
`62.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`63.
`
`The allegations in this paragraph contain subjective assessments from Plaintiffs
`
`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
`
`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
`
`7
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 50 Filed 01/26/15 Page 8 of 572 PageID# 1225
`
`64.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`65.
`
`The allegations in this paragraph contain subjective assessments from Plaintiffs
`
`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
`
`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
`
`66.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`67.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`68.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`69.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`70.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`71.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`72.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`73.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`74.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`8
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 50 Filed 01/26/15 Page 9 of 572 PageID# 1226
`
`75.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`REFERENCES
`
`76.
`
`This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`77.
`
`This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`78.
`
`This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`79.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`80.
`
`This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`81.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`9
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 50 Filed 01/26/15 Page 10 of 572 PageID# 1227
`
`82.
`
`This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`83.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`84.
`
`This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`85.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`86.
`
`This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`87.
`
`Defendant avers that the referenced document speaks for itself, and otherwise
`
`denies the allegations of this paragraph, including all characterizations of the document beyond
`
`the text of the document and distortions via selective excerpts.
`
`88.
`
`This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`10
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 50 Filed 01/26/15 Page 11 of 572 PageID# 1228
`
`89.
`
`Defendant avers that the referenced document speaks for itself, and otherwise
`
`denies the allegations of this paragraph, including all characterizations of the document beyond
`
`the text of the document and distortions via selective excerpts.
`
`90.
`
`Defendant avers that the referenced document speaks for itself, and otherwise
`
`denies the allegations of this paragraph, including all characterizations of the document beyond
`
`the text of the document and distortions via selective excerpts.
`
`91.
`
`Defendant admits that the GF100 GPU is based on the Fermi microarchitecture,
`
`and denies any remaining allegations in this paragraph.
`
`92.
`
`Defendant avers that the referenced document speaks for itself, and otherwise
`
`denies the allegations of this paragraph, including all characterizations of the document beyond
`
`the text of the document and distortions via selective excerpts.
`
`93.
`
`This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`94.
`
`Defendant avers that the referenced document speaks for itself, and otherwise
`
`denies the allegations of this paragraph, including all characterizations of the document beyond
`
`the text of the document and distortions via selective excerpts.
`
`95.
`
`Defendant avers that the referenced document speaks for itself, and otherwise
`
`denies the allegations of this paragraph, including all characterizations of the document beyond
`
`the text of the document and distortions via selective excerpts.
`
`96.
`
`Defendant admits that the GK110 GPU is based on the Kepler microarchitecture,
`
`and denies any remaining allegations in this paragraph.
`
`11
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 50 Filed 01/26/15 Page 12 of 572 PageID# 1229
`
`97.
`
`Defendant avers that the referenced document speaks for itself, and otherwise
`
`denies the allegations of this paragraph, including all characterizations of the document beyond
`
`the text of the document and distortions via selective excerpts.
`
`98.
`
`This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`99.
`
`Defendant avers that the referenced document speaks for itself, and otherwise
`
`denies the allegations of this paragraph, including all characterizations of the document beyond
`
`the text of the document and distortions via selective excerpts.
`
`100. Defendant avers that the referenced document speaks for itself, and otherwise
`
`denies the allegations of this paragraph, including all characterizations of the document beyond
`
`the text of the document and distortions via selective excerpts.
`
`101. Defendant admits
`
`that
`
`the GM107 GPU
`
`is based on
`
`the Maxwell
`
`microarchitecture, and denies any remaining allegations in this paragraph.
`
`102. Defendant avers that the referenced document speaks for itself, and otherwise
`
`denies the allegations of this paragraph, including all characterizations of the document beyond
`
`the text of the document and distortions via selective excerpts.
`
`103. This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`12
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 50 Filed 01/26/15 Page 13 of 572 PageID# 1230
`
`104. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`105. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`106. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`107. The accuracy of the allegations contained in this paragraph depends on context
`
`and the paragraph contains subjective assessments from Plaintiffs. Thus, Defendant lacks
`
`knowledge or information sufficient to form a belief as to the truth or falsity of the allegations
`
`contained in this paragraph and therefore denies them.
`
`108. This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`109. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`110. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`111. This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`13
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 50 Filed 01/26/15 Page 14 of 572 PageID# 1231
`
`112. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`113. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`114. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`115. The accuracy of the allegations contained in this paragraph depends on context
`
`and the paragraph contains subjective assessments from Plaintiffs. Thus, Defendant lacks
`
`knowledge or information sufficient to form a belief as to the truth or falsity of the allegations
`
`contained in this paragraph and therefore denies them.
`
`116. This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`117. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`118. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`119. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`120. The accuracy of the allegations contained in this paragraph depends on context
`
`and the paragraph contains subjective assessments from Plaintiffs. Thus, Defendant lacks
`
`14
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 50 Filed 01/26/15 Page 15 of 572 PageID# 1232
`
`knowledge or information sufficient to form a belief as to the truth or falsity of the allegations
`
`contained in this paragraph and therefore denies them.
`
`121. This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`122. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`123. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`124. Defendant denies the allegations in this paragraph.
`
`125. Defendant admits that the GK107 GPU is based on the Kepler microarchitecture,
`
`and denies any remaining allegations in this paragraph.
`
`126. This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`127. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`128. This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`15
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 50 Filed 01/26/15 Page 16 of 572 PageID# 1233
`
`129. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`130. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`131. This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`132. This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`133. This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`134. This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`135. Defendant is witho