`
`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
`
`JURY TRIAL DEMANDED
`
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`DEFENDANT OLD MICRO, INC.’S ANSWER TO AMENDED COMPLAINT
`
`Defendant Old Micro, Inc. (“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 in 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 in this paragraph, and on that basis denies them.
`
`3.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`4.
`
`5.
`
`Defendant denies the allegations in this paragraph.
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`Defendant admits the allegations in this paragraph.
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`
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`Case 3:14-cv-00757-REP-DJN Document 51 Filed 01/26/15 Page 2 of 378 PageID# 1791
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`SAMSUNG
`
`6.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in 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 in 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 in 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 in 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 in 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 in 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 in 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 in 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 in this paragraph, and on that basis denies them.
`
`15.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in 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 in this paragraph, and on that basis denies them.
`
`2
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`
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`Case 3:14-cv-00757-REP-DJN Document 51 Filed 01/26/15 Page 3 of 378 PageID# 1792
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`NVIDIA
`
`17.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`18.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`19.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`20.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`21.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`VELOCITY
`
`22.
`
`Defendant admits
`
`that Velocity Holdings, LLC produces custom high-
`
`performance computers designed for gaming, digital graphic design, home theater use, and
`
`common home and office use and that Velocity Holdings, LLC provides scientific workstations.
`
`Defendant denies the remaining allegations.
`
`23.
`
`Defendant avers that the referenced documents speak for themselves, and
`
`otherwise denies the allegations of this paragraph, including all characterizations of the
`
`documents beyond the text of the document and distortions via selective excerpts.
`
`24.
`
`Defendant avers that the referenced documents speak for themselves, and
`
`otherwise denies the allegations of this paragraph, including all characterizations of the
`
`documents beyond the text of the document and distortions via selective excerpts.
`
`3
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`
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`Case 3:14-cv-00757-REP-DJN Document 51 Filed 01/26/15 Page 4 of 378 PageID# 1793
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`25.
`
`Defendant avers that the referenced documents speak for themselves, and
`
`otherwise denies the allegations of this paragraph, including all characterizations of the
`
`documents beyond the text of the document and distortions via selective excerpts.
`
`26.
`
`Defendant avers that the referenced documents speak for themselves, and
`
`otherwise denies the allegations of this paragraph, including all characterizations of the
`
`documents beyond the text of the document and distortions via selective excerpts.
`
`27.
`
`Defendant avers that the referenced documents speak for themselves, and
`
`otherwise denies the allegations of this paragraph, including all characterizations of the
`
`documents beyond the text of the document and distortions via selective excerpts.
`
`28.
`
`Defendant avers that the referenced documents speak for themselves, and
`
`otherwise denies the allegations of this paragraph, including all characterizations of the
`
`documents beyond the text of the document and distortions via selective excerpts.
`
`29.
`
`Defendant admits that Velocity Holdings, LLC sells computers, some of which
`
`may incorporate NVIDIA GPUs, and denies all remaining allegations in this paragraph.
`
`30.
`
`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.
`
`31.
`
`Defendant admits that Velocity Holdings, LLC sells products and services in the
`
`Commonwealth of Virginia. Defendant denies that they infringe any valid and enforceable claim
`
`of the Asserted Patents. Defendant avers that the referenced document speaks for itself, and
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`otherwise denies the remaining allegations of this paragraph, including all characterizations of
`
`the documents beyond the text of the document and distortions via selective excerpt
`
`4
`
`
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`Case 3:14-cv-00757-REP-DJN Document 51 Filed 01/26/15 Page 5 of 378 PageID# 1794
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`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
`
`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.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`34.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`35.
`
`Defendant admits that Velocity Holdings, LLC conducts business activities within
`
`the Commonwealth of Virginia, but denies that they infringe any valid and enforceable claim of
`
`the Asserted Patents. To the extent this paragraph also contains conclusions of law and not
`
`averments of facts to which an answer is required, but insofar as an answer may be deemed
`
`required, Defendant denies them.
`
`36.
`
`Defendant admits that Velocity Holdings, LLC sells products nationwide,
`
`including in Virginia, but denies that they infringe any valid and enforceable claim of the
`
`Asserted Patents, and denies all other allegations in this paragraph.
`
`37.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`38.
`
`Defendant avers that the referenced documents speak for themselves, and
`
`otherwise denies the allegations of this paragraph, including all characterizations of the
`
`documents beyond the text of the document and distortions via selective excerpts.
`
`39.
`
`Defendant admits that Old Micro, Inc. was registered as a corporation with the
`
`Commonwealth of Virginia and appointed as its registered agent Freed & Shepherd, P.C., 9030
`
`5
`
`
`
`Case 3:14-cv-00757-REP-DJN Document 51 Filed 01/26/15 Page 6 of 378 PageID# 1795
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`Stony Point Pkwy Suite 400, Richmond, VA 23235, and denies any remaining allegations in this
`
`paragraph.
`
`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 in 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 in 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 in this paragraph, and on that basis denies them.
`
`44.
`
`45.
`
`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 in 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 in 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 in 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.
`
`6
`
`
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`Case 3:14-cv-00757-REP-DJN Document 51 Filed 01/26/15 Page 7 of 378 PageID# 1796
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`51.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in 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 in 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.
`
`55.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in 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 in 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 in 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.
`
`7
`
`
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`Case 3:14-cv-00757-REP-DJN Document 51 Filed 01/26/15 Page 8 of 378 PageID# 1797
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`60.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in 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 in 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.
`
`64.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in 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 in 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 in 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 in 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 in this paragraph, and on that basis denies them.
`
`8
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`Case 3:14-cv-00757-REP-DJN Document 51 Filed 01/26/15 Page 9 of 378 PageID# 1798
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`70.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in 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 in 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 in 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 in this paragraph, and on that basis denies them.
`
`74.
`
`Defendant admits that the NoteMagix M15, NoteMagix M17, NoteMagix M15
`
`Ultra, and NoteMagix M17 Ultra may include DisplayPort, and denies any remaining
`
`allegations.
`
`75.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in 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
`
`9
`
`
`
`Case 3:14-cv-00757-REP-DJN Document 51 Filed 01/26/15 Page 10 of 378 PageID# 1799
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`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 avers that the referenced documents speak for themselves, and
`
`otherwise denies the allegations of this paragraph, including all characterizations of the
`
`documents beyond the text of the document and distortions via selective excerpts.
`
`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 avers that the referenced documents speak for themselves, and
`
`otherwise denies the allegations of this paragraph, including all characterizations of the
`
`documents beyond the text of the document and distortions via selective excerpts.
`
`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 avers that the referenced documents speak for themselves, and
`
`otherwise denies the allegations of this paragraph, including all characterizations of the
`
`documents beyond the text of the document and distortions via selective excerpts.
`
`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.
`
`10
`
`
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`Case 3:14-cv-00757-REP-DJN Document 51 Filed 01/26/15 Page 11 of 378 PageID# 1800
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`85.
`
`Defendant avers that the referenced documents speak for themselves, and
`
`otherwise denies the allegations of this paragraph, including all characterizations of the
`
`documents beyond the text of the document and distortions via selective excerpts.
`
`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 is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`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.
`
`89.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`90.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`91.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`92.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`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
`
`11
`
`
`
`Case 3:14-cv-00757-REP-DJN Document 51 Filed 01/26/15 Page 12 of 378 PageID# 1801
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`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 is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`95.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`96.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`97.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`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 is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`100. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`101. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`102. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`12
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`
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`Case 3:14-cv-00757-REP-DJN Document 51 Filed 01/26/15 Page 13 of 378 PageID# 1802
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`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.
`
`104. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in 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 in 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 in this paragraph, and on that basis denies them.
`
`107. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis 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 in 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 in 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
`
`13
`
`
`
`Case 3:14-cv-00757-REP-DJN Document 51 Filed 01/26/15 Page 14 of 378 PageID# 1803
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`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.
`
`112. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in 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 in 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 in this paragraph, and on that basis denies them.
`
`115. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis 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 in 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 in 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 in this paragraph, and on that basis denies them.
`
`120. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`14
`
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`121. This paragraph contains no factual allegations that require a response, but to the
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`extent a response is required, Defendant admits that Plaintiffs produced a document so
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`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
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`any remaining allegations set forth in this paragraph, and on that basis denies them.
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`122. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`123. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`124. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`125. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`126. This paragraph contains no factual allegations that require a response, but to the
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`extent a response is required, Defendant admits that Plaintiffs produced a document so
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`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
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`any remaining allegations set forth in this paragraph, and on that basis denies them.
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`127. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`128. This paragraph contains no factual allegations that require a response, but to the
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`extent a response is required, Defendant admits that Plaintiffs produced a document so
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`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
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`any remaining allegations set forth in this paragraph, and on that basis denies them.
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`15
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`129. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`130. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`131. This paragraph contains no factual allegations that require a response, but to the
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`extent a response is required, Defendant admits that Plaintiffs produced a document so
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`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
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`any remaining allegations set forth in this paragraph, and on that basis denies them.
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`132. This paragraph contains no factual allegations that require a response, but to the
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`extent a response is required, Defendant admits that Plaintiffs produced a document so
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`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
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`any remaining allegations set forth in this paragraph, and on that basis denies them.
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`133. This paragraph contains no factual allegations that require a response, but to the
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`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
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`any remaining allegations set forth in this paragraph, and on that basis denies them.
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`134. This paragraph contains no factual allegations that require a response, but to the
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`extent a response is required, Defendant admits that Plaintiffs produced a document so
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`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.
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`135. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`16
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`Case 3:14-cv-00757-REP-DJN Document 51 Fil