Case 3:14-cv-00757-REP-DJN Document 59 Filed 03/03/15 Page 1 of 766 PageID# 4398
`
`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
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`DEFENDANT NVIDIA CORPORATION’S FIRST AMENDED ANSWER TO
`AMENDED COMPLAINT
`
`Defendant NVIDIA Corporation (“NVIDIA” or “Defendant”), by and through its
`
`undersigned attorneys, hereby file this First Amended Answer to Plaintiffs Samsung Electronics
`
`Company, Ltd. (“SEC”) and Samsung Electronics America, Inc.’s (“SEA”) (collectively
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`“Plaintiffs” or “Samsung”) First Amended Complaint. Defendant states as follows:
`
`THE PARTIES
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`1.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth within this paragraph, and on that basis denies them.
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`2.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth within this paragraph, and on that basis denies them.
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`3.
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`Defendant admits that it is a Delaware corporation with its principal place of
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`business at 2701 San Tomas Expressway, Santa Clara, California 95050. Defendant further
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`admits that it imports into the United States, offers for sale, sells and/or uses in the United States
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`certain graphics processing units and/or systems-on-a-chip, and denies any remaining allegations
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`in this paragraph.
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`

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`4.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth within this paragraph, and on that basis denies them.
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`5.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth within this paragraph, and on that basis denies them.
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`SAMSUNG
`
`6.
`
`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`7.
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`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.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`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.
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`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.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`12.
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`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.
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`13.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth within this paragraph, and on that basis denies them.
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`14.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth within this paragraph, and on that basis denies them.
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`2
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`15.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth within this paragraph, and on that basis denies them.
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`16.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`NVIDIA
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`17.
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`Defendant admits that it designs, develops, supplies, and sells graphics processing
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`units and mobile system-on-chip products. The accuracy of the remaining allegations contained
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`in this paragraph depends on context and the paragraph contains subjective assessments from
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`Plaintiffs. Thus, Defendant lacks knowledge or information sufficient to form a belief as to the
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`truth or falsity of the remaining allegations contained in this paragraph and therefore denies
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`them.
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`18.
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`Defendant admits that it sells a device named the Shield Tablet. Defendant
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`further admits that the Shield Tablet supports the Android operating system. Defendants are
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`without knowledge or information sufficient to form a belief as to the truth of the remaining
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`allegations set forth in this paragraph, and on that basis deny them.
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`19.
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`Defendant admits that it sells products and services through the United States,
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`including in Virginia, and denies any remaining allegations in this paragraph.
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`20.
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`Defendant admits that it sells products nationwide, including in Virginia.
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`Defendant further avers that the referenced document speaks for itself, and denies all other
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`allegations in this paragraph.
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`21.
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`Defendant admits that it is registered as a foreign corporation with the
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`Commonwealth of Virginia and may be served with process through its registered agent,
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`Corporation Service Company, 1111 East Main Street, Richmond, VA 23219.
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`VELOCITY
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`3
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`22.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth within this paragraph, and on that basis denies them.
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`23.
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`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.
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`24.
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`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.
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`25.
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`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.
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`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.
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`27.
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`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.
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`28.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth within this paragraph, and on that basis denies them.
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`29.
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`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.
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`30.
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`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.
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`31.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth within this paragraph, and on that basis denies them.
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`JURISDICTION AND VENUE
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`32.
`
`Defendant admits that this action purports to arise under the patent laws of the
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`United States, Title 35 of the United States Code, but denies that this action has any merit or that
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`4
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`Plaintiffs are entitled to the relief sought. Defendant also admits that this Court has subject
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`matter jurisdiction, but denies the remaining allegations of this paragraph.
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`33.
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`34.
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`35.
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`Defendant denies the allegations in this paragraph.
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`Defendant denies the allegations in this paragraph.
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`Defendant denies the legal argument improperly included in this paragraph, and
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`denies all remaining factual allegations.
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`36.
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`Defendant admits that it sells products nationwide, including in Virginia, and
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`denies all other allegations in this paragraph.
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`37.
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`Defendant admits that it is registered as a foreign corporation with the
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`Commonwealth of Virginia and may be served with process through its registered agent,
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`Corporation Service Company, 1111 East Main Street, Richmond, VA 23219.
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`38.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth within this paragraph, and on that basis denies them.
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`39.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth within this paragraph, and on that basis denies them.
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`40.
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`Defendant denies the allegations in this paragraph.
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`ACCUSED PRODUCTS
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`41.
`
`Defendant admits that the Amended Complaint defines the term “Accused
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`Products” to include “Accused GPUs” and “Accused SOCs” and all products that contain an
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`“Accused GPU” or “Accused SOC” that have been made, sold, or offered for sale, or imported
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`into the United States at any time since November 4, 2008. Defendant denies that Defendant
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`infringes any valid and enforceable claim of the asserted patents. Defendant denies any
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`remaining allegations.
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`5
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`42.
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`Defendant admits that the Amended Complaint defines the term “Accused GPUs”
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`to include “all NVIDIA GPUs and all products that contain a NVIDIA GPU that have been
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`made, used, sold, offered for sale, or imported into the United States since November 4, 2008,
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`including the products identified in paragraphs 43 to 55.” Defendant denies that Defendant
`
`infringes any valid and enforceable claim of the asserted patents. Defendant denies any
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`remaining allegations.
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`43.
`
`Defendant admits that the Amended Complaint defines the term “938 Accused
`
`GPUs” to include “all NVIDIA GPUs and all products that contain NVIDIA GPUs that are
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`designed to operate in conjunction with JEDEC standard SDRAM or SGRAM that includes
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`posted CAS latency functionality or any equivalent thereof.” Defendant denies that Defendant
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`infringes any valid and enforceable claim of the asserted patents. Defendant denies any
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`remaining allegations.
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`44.
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`This allegation relies on a term found in the claims of the ’938 patent. To the
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`extent this paragraph makes allegations regarding the alleged invention and the scope of the
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`claims, Defendant denies such allegations. Because Plaintiffs have not provided an interpretation
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`or construction for this term and “posted CAS latency functionality or any equivalent thereof,”
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`this allegation contains unstated subjective assessments from Plaintiffs and the accuracy of the
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`allegations depends on context. Defendant lacks knowledge or information sufficient to form a
`
`belief as to the truth of the allegations, and therefore denies them.
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`45.
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`Defendant admits that the Amended Complaint defines the term “602 Accused
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`GPUs” to include “all NVIDIA GPUs and all products that contain NVIDIA GPUs that are
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`designed to support any SDRAM or SGRAM that includes an input data strobe feature
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`supporting single-ended and differential signaling or any equivalent thereof.” Defendant denies
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`6
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`that Defendant infringes any valid and enforceable claim of the asserted patents. Defendant
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`denies any remaining allegations.
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`46.
`
`47.
`
`Defendant denies the allegations in this paragraph.
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`Defendant admits that the Amended Complaint defines the term “Accused 28 nm
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`GPUs” to include “all NVIDIA GPUs utilizing 28 nanometer fabrication processing and all
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`products that contain such a GPU.” Defendant denies that Defendant infringes any valid and
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`enforceable claim of the asserted patents. Defendant denies any remaining allegations.
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`48.
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`Defendant admits that, depending on context, certain identified products could be
`
`considered to be fabricated by a 28 nanometer process. The phrase “fabricated utilizing a 28
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`nanometer fabrication processing” is vague and ambiguous at least because Samsung has not
`
`explained what it means by “28 nanometer fabrication processing.” Defendant therefore is
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`without knowledge or information sufficient to form a belief as to the truth of any remaining
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`allegations set forth in this paragraph, and on that basis denies them.
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`49.
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`Defendant admits that the Amended Complaint defines the term “Accused 40 nm
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`and Other GPUs” to include “all NVIDIA GPUs utilizing 40 nanometer, 55 nanometer, 65
`
`nanometer, 80 nanometer, or 90 nanometer fabrication processing and all products that contain
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`such a GPU.” Defendant denies that Defendant infringes any valid and enforceable claim of the
`
`asserted patents. Defendant denies any remaining allegations.
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`50.
`
`Defendant admits that, depending on context, certain identified products could be
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`considered to be fabricated by a 40 nanometer, 55 nanometer, 65 nanometer, 80 nanometer, or 90
`
`nanometer process. The phrase “fabricated utilizing 40 nanometer, 55 nanometer, 65 nanometer,
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`80 nanometer, or 90 nanometer fabrication processing” is vague and ambiguous at least because
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`Samsung has not explained what it means by “40 nanometer, 55 nanometer, 65 nanometer, 80
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`7
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`nanometer, or 90 nanometer fabrication processing.” Defendant therefore is without knowledge
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`or information sufficient to form a belief as to the truth of any remaining allegations set forth in
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`this paragraph, and on that basis denies them.
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`51.
`
`Defendant admits that the Amended Complaint defines the term “’724 Accused
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`Mobile GPUs” to include “all NVIDIA GPUs that support DisplayPort and that are used, or
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`intended for use, in laptop computers.” Defendant denies that Defendant infringes any valid and
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`enforceable claim of the asserted patents. Defendant denies any remaining allegations.
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`52.
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`Defendant admits that certain identified products may contain an NVIDIA GPU
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`that supports DisplayPort and can be used in a laptop computer, depending on the context in
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`which these terms are used. This allegation relies on terms found in the claims of the ’724 patent
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`and contains legal arguments and conclusions; therefore, no answer is required. To the extent an
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`answer is required and this paragraph makes allegations regarding the alleged invention and the
`
`scope of the claims, Defendant denies such allegations. Defendant's responses are not intended
`
`to interpret the meaning or scope of the claims in the ’724 patent. Because Plaintiffs have not
`
`provided an interpretation or construction for this term, this allegation contains unstated
`
`subjective assessments from Plaintiffs and the accuracy of the allegations depends on context.
`
`Defendant lacks knowledge or information sufficient to form a belief as to the truth of the
`
`allegations, and therefore denies them. Defendant states that it does not infringe any valid and
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`enforceable claim of the ’724 patent.
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`53.
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`Defendant admits that the Amended Complaint defines the term “724 Accused
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`Mobile GPUs with Analog Output” to include “all NVIDIA GPUs that support DisplayPort and
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`an analog output, such as DVI or VGA, and that are intended for use or used in laptop
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`8
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`computers.” Defendant denies that Defendant infringes any valid and enforceable claim of the
`
`asserted patents. Defendant denies any remaining allegations.
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`54.
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`Defendant admits that certain identified products may contain an NVIDIA GPU
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`that supports DisplayPort, DVI and/or VGA, and that is used, or intended for use, in a laptop
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`computer, depending on the context in which these terms are used. This allegation relies on
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`terms found in the claims of the ’724 patent and contains legal arguments and conclusions;
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`therefore, no answer is required. To the extent an answer is required and this paragraph makes
`
`allegations regarding the alleged invention and the scope of the claims, Defendant denies such
`
`allegations. Defendant's responses are not intended to interpret the meaning or scope of the
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`claims in the ’724 patent. Because Plaintiffs have not provided an interpretation or construction
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`for this term, this allegation contains unstated subjective assessments from Plaintiffs and the
`
`accuracy of the allegations depends on context. Defendant lacks knowledge or information
`
`sufficient to form a belief as to the truth of the allegations, and therefore denies them. Defendant
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`states that it does not infringe any valid and enforceable claim of the ’724 patent.
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`55.
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`Defendant admits that the Amended Complaint defines the term “Unified Cache
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`GPUs” to include “all NVIDIA GPUs that include a unified L2 cache, as well as all products that
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`contain such a GPU.” Defendant denies that Defendant infringes any valid and enforceable
`
`claim of the asserted patents. Defendant denies any remaining allegations.
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`56.
`
`Defendant admits, based on its present understanding, certain identified products
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`may be or may contain an NVIDIA GPU with a unified L2 cache, depending on the context in
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`which these terms are used. Defendant further admits that certain of the identified products are
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`based on the Fermi, Kepler, or Maxwell microarchitectures. This allegation relies on terms
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`found in the claims of the ’158 patent and contains legal arguments and conclusions; therefore,
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`9
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`no answer is required. To the extent an answer is required and this paragraph makes allegations
`
`regarding the alleged invention and the scope of the claims, Defendant denies such allegations.
`
`Defendant's responses are not intended to interpret the meaning or scope of the claims in the
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`’158 patent. Because Plaintiffs have not provided an interpretation or construction for this term,
`
`this allegation contains unstated subjective assessments from Plaintiffs and the accuracy of the
`
`allegations depends on context. Defendant lacks knowledge or information sufficient to form a
`
`belief as to the truth of the allegations, and therefore denies them. Defendant states that it does
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`not infringe any valid and enforceable claim of the ’158 patent.
`
`57.
`
`Defendant admits that the Amended Complaint defines the term “Accused SOCs”
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`to include “all NVIDIA SOCs and all products that contain a NVIDIA SOC that have been
`
`made, used, sold, offered for sale, or imported into the United States at any time since November
`
`4, 2008.” Defendant denies that Defendant infringes any valid and enforceable claim of the
`
`asserted patents. Defendant denies any remaining allegations.
`
`58.
`
`Defendant admits that the Amended Complaint defines the term “Accused 28 nm
`
`SOCs” to include “all NVIDIA SOCs utilizing 28 nanometer fabrication processing and all
`
`products that contain such an SOC.” Defendant denies that Defendant infringes any valid and
`
`enforceable claim of the asserted patents. Defendant denies any remaining allegations.
`
`59.
`
`Defendant admits that, depending on context, certain identified products could be
`
`considered to be fabricated by a 28 nanometer process. The phrase “fabricated utilizing a 28
`
`nanometer fabrication processing” is vague and ambiguous at least because Samsung has not
`
`explained what it means by “28 nanometer fabrication processing.” Defendant therefore is
`
`without knowledge or information sufficient to form a belief as to the truth of any remaining
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`allegations set forth in this paragraph, and on that basis denies them.
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`10
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`60.
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`Defendant admits that the Amended Complaint defines the term “Accused 40 nm
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`and Other SOCs” to include “all NVIDIA SOCs utilizing 40 nanometer, 55 nanometer, 65
`
`nanometer, 80 nanometer, or 90 nanometer fabrication processing and all products that contain
`
`such a SOC.” Defendant denies that Defendant infringes any valid and enforceable claim of the
`
`asserted patents. Defendant denies any remaining allegations.
`
`61.
`
`Defendant admits that, depending on context, certain identified products could be
`
`considered to be fabricated by a 40 nanometer, 55 nanometer, 65 nanometer, 80 nanometer, or 90
`
`nanometer process. The phrase “fabricated utilizing 40 nanometer, 55 nanometer, 65 nanometer,
`
`80 nanometer, or 90 nanometer fabrication processing” is vague and ambiguous at least because
`
`Samsung has not explained what it means by “40 nanometer, 55 nanometer, 65 nanometer, 80
`
`nanometer, or 90 nanometer fabrication processing.” Defendant therefore is without knowledge
`
`or information sufficient to form a belief as to the truth of any remaining allegations set forth in
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`this paragraph, and on that basis denies them.
`
`62.
`
`Defendant admits that the Amended Complaint defines the term “Cortex-A9
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`SOCs” to include “all NVIDIA SOCs based on the ARM Cortex-A9 design and all products that
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`contain such an SOC.” Defendant denies that Defendant infringes any valid and enforceable
`
`claim of the asserted patents. Defendant denies any remaining allegations.
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`63.
`
`Defendant admits that depending on context, certain identified products may be
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`based on the ARM Cortex-A9 design. This allegation is vague and ambiguous at least because
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`Samsung has not explained what it means by “based on the ARM Cortex-A9 design.” Defendant
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`therefore is without knowledge or information sufficient to form a belief as to the truth of any
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`remaining allegations set forth in this paragraph, and on that basis denies them.
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`11
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`64.
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`Defendant admits that the Amended Complaint defines the term “Cortex-A15
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`SOCs” to include “all NVIDIA SOCs based on the ARM Cortex-A15 design and all products
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`that contain such an SOC.” Defendant denies that Defendant infringes any valid and enforceable
`
`claim of the asserted patents. Defendant denies any remaining allegations.
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`65.
`
`Defendant admits that depending on context, certain identified products may be
`
`based on the ARM Cortex-A15 design. This allegation is vague and ambiguous at least because
`
`Samsung has not explained what it means by “based on the ARM Cortex-A15 design.”
`
`Defendant therefore 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.
`
`66.
`
`Defendant admits that the Amended Complaint defines the term “’158 Accused
`
`Products” to include “Accused SOCs” and “Unified Cache GPUs.” Defendant denies that
`
`Defendant infringes any valid and enforceable claim of the asserted patents. Defendant denies
`
`any remaining allegations.
`
`67.
`
`Defendant admits that the Amended Complaint defines the term “938 Accused
`
`Products” to include “Accused SOCs” and “’938 Accused GPUs” and/or all systems containing
`
`any of the “Acused SOCs” or “‘938 Accused GPUs”. Defendant denies that Defendant infringes
`
`any valid and enforceable claim of the asserted patents. Defendant denies any remaining
`
`allegations.
`
`68.
`
`Defendant admits that the Amended Complaint defines the term “902 Accused
`
`Products” to include “Accused Products.” Defendant denies that Defendant infringes any valid
`
`and enforceable claim of the asserted patents. Defendant denies any remaining allegations.
`
`69.
`
`Defendant admits that the Amended Complaint defines the term “602 Accused
`
`Products” to include “602 Accused GPUs” and “Accused SOCs.” Defendant denies that
`
`12
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`Defendant infringes any valid and enforceable claim of the asserted patents. Defendant denies
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`any remaining allegations.
`
`70.
`
`Defendant admits that the Amended Complaint defines the term “675 Accused
`
`Products” to include “Accused 28 nm GPUs” and “Accused 28 nm SOCs.” Defendant denies
`
`that Defendant infringes any valid and enforceable claim of the asserted patents. Defendant
`
`denies any remaining allegations.
`
`71.
`
`Defendant admits that the Amended Complaint defines the term “054 Accused
`
`Products” to include “all Velocity computer products that contain a hybrid hard drive—that is, a
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`hard drive with both a spinning platter and separate, solid-state non-volatile storage capacity—
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`that have been made, used, sold, offered for sale, or imported into the United States at any time
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`since November 4, 2008.” Defendant denies that Defendant infringes any valid and enforceable
`
`claim of the asserted patents. Defendant denies any remaining allegations.
`
`72.
`
`Defendant admits that the Amended Complaint defines the term “854 Accused
`
`Products” to include “all Velocity computers and computer cases that include flexible contacts
`
`on the computer case.” Defendant denies that Defendant infringes any valid and enforceable
`
`claim of the asserted patents. Defendant denies any remaining allegations.
`
`73.
`
`Defendant admits that the Amended Complaint defines the term “724 Accused
`
`Velocity Laptop” to include “all Velocity laptop computers with a DisplayPort port.” Defendant
`
`denies that Defendant infringes any valid and enforceable claim of the asserted patents.
`
`Defendant denies any remaining allegations.
`
`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.
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`13
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`75.
`
`Defendant admits that the Amended Complaint defines the term “724 Accused
`
`Products” to include “724 Accused Velocity Laptops”, “724 Accused Mobile GPUs”, and all
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`laptop computers containing “724 Accused Mobile GPUs.” Defendant denies that Defendant
`
`infringes any valid and enforceable claim of the asserted patents. Defendant denies any
`
`remaining allegations.
`
`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.
`
`14
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`Case 3:14-cv-00757-REP-DJN Document 59 Filed 03/03/15 Page 15 of 766 PageID# 4412
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`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.
`
`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 admits that the document identified in this paragraph appears to be a
`
`printout incorporating images and text from NVIDIA’s website, but denies that it is a true and
`
`accurate copy of an NVIDIA webpage. To the extent this paragraph contains conclusions of law
`
`and not averments of facts, no answer is required.
`
`15
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`Case 3:14-cv-00757-REP-DJN Document 59 Filed 03/03/15 Page 16 of 766 PageID# 4413
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`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 admits that the document identified in this paragraph appears to be a
`
`copy of a document published by NVIDIA in or around 2010. To the extent this paragraph
`
`contains conclusions of law and not averments of facts, no answer is required. Defendant
`
`otherwise denies the allegations of this paragraph, including all characterizations of the
`
`document.
`
`90.
`
`Defendant admits that in the context that the identified document is normally
`
`used, it describes certain aspects and configurations of the NVIDIA GF100 GPU and appears to
`
`be accurate in that context. Defendant otherwise denies the allegations of this paragraph,
`
`including all characterizations of the document.
`
`91.
`
`Defendant admits that the GF100 GPU is based on the Fermi microarchitecture,
`
`and denies any remaining allegations in this paragraph.
`
`92.
`
`Defendant admits that in the context that the identified document is normally
`
`used, it appears to accurately describe certain aspects of the Fermi microarchitecture. Defendant
`
`otherwise denies the allegations of this paragraph, including all characterizations of the
`
`document.
`
`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.
`
`16
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`Case 3:14-cv-00757-REP-DJN Document 59 Filed 03/03/15 Page 17 of 766 PageID# 4414
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`94.
`
`Defendant admits that the document identified in this paragraph appears to be a
`
`copy of a document published by NVIDIA in or around 2012. To the extent this paragraph
`
`contains conclusions of law and not averments of facts, no answer is required. Defendant
`
`otherwise denies