Case 3:14-cv-00757-REP-DJN Document 61 Filed 03/03/15 Page 1 of 441 PageID# 5610
`
`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
`
`
`)
`)
`)
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`)
`
`DEFENDANT OLD MICRO, INC.’S FIRST AMENDED ANSWER
`TO AMENDED COMPLAINT
`
`Defendant Old Micro, Inc. (“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 “Plaintiffs” or
`
`“Samsung”) First Amended Complaint. Defendant states as follows:
`
`THE PARTIES
`
`1.
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`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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`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.
`
`Defendant admits the allegations in this paragraph.
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`

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`SAMSUNG
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`6.
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`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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`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-
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`performance computers designed for gaming, digital graphic design, home theater use, and
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`common home and office use and that Velocity Holdings, LLC provides scientific workstations.
`
`Defendant denies the remaining allegations.
`
`23.
`
`Defendant admits that the referenced documents About Velocity and Velocity
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`Gaming
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`and Enthusiast Laptops
`
`are
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`copies of webpages
`
`from
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`the website
`
`http://www.velocitymicro.com and state that it is “the premier high-performance innovator of
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`consumer technology and electronics in North America,” that it is “100% based in the USA in
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`Richmond, VA,” and that some computers are “[a]ssembled by our expert engineers in
`
`Richmond, VA.” Defendant admits that the referenced document Configure Your M17 includes
`
`the text “Careful custom integration and testing, final assembly by hand in Richmond, Virginia,
`
`USA” under the section “Support.” Defendant otherwise denies the allegations of this
`
`3
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`

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`paragraph, including all characterizations of the documents beyond the text of the document and
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`distortions via selective excerpts.
`
`24.
`
`Defendant admits that the referenced documents are copies of webpages from the
`
`website http://www.velocitymicro.com and state “the immediate availability of the NVIDIA
`
`GeForce GTX 750, GTX 750 Ti, and
`
`the amazing GTX TITAN Black
`
`in select
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`Gaming/Enthusiast and Workstation desktops” and “‘Every evolution of the GeForce cards
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`presents better and better choices for consumers, and these new products are no exception,’ said
`
`Randy Copeland, President and CEO of Velocity. ‘With the best-in-class performance of the
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`TITAN Black and incredible price for performance of the GTX 750 and 750 Ti, NVIDIA has
`
`brought two great choices to market. We’re excited to offer them to our enthusiast customers.’”
`
`Defendant otherwise denies the allegations of this paragraph, including all characterizations of
`
`the documents beyond the text of the document and distortions via selective excerpts.
`
`25.
`
`Defendant admits that the referenced documents are copies of webpages from the
`
`website http://www.velocitymicro.com and state “desktops powered by NVIDIA GeForce GTX
`
`780” and “‘Since our first Editors’ Choice award in 2002, we’ve seen PC hardware come a long
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`way. NVIDIA has always led the way in that innovation,’ said Randy Copeland, President and
`
`CEO of Velocity. ‘After spending a few days testing the GeForce GTX 780, all I can say is
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`WOW – they’ve done it again. This is seriously fast hardware and a must have for enthusiasts.”
`
`Defendant 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 admits that the referenced documents are copies of webpages from the
`
`website http://www.velocitymicro.com and state “Raptor X17 Notebook Featuring NVIDIA®
`
`GeForce® GTX 480M Mobile Graphics” and “‘With the release of the NVIDIA GeForce GTX
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`4
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`480M, we’re able to provide a new level of mobile gaming performance to our customers who
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`demand the best hardware,’ said Chip Lowell, VP of Sales for Velocity. ‘This is more than just a
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`desktop replacement. It’s the ultimate mobile gaming system.’” Defendant otherwise denies the
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`allegations of this paragraph, including all characterizations of the documents beyond the text of
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`the document and distortions via selective excerpts.
`
`27.
`
`Defendant admits that it issues press releases and that it has sold computers
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`including NVIDIA graphics cards. The referenced document is a press release titled “Velocity
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`Micro Announces the Immediate Availability of NVIDIA GeForce GTX 750, 750 Ti, and
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`TITAN Black Graphics.” Defendant 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 admits that the referenced documents are copies of webpages from the
`
`website http://www.velocitymicro.com and state “Velocity Micro Partners With NVIDIA To
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`Launch GeForce 6 Series of Graphics” and “‘We’re pleased to be able to launch such compelling
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`technology in conjunction with a well-respected company like NVIDIA,’ said Velocity founder
`
`and president Randall Copeland. ‘This partnership is just one of the many reasons why Velocity
`
`Micro is able to offer premium products to meet the needs of all its customers.’” Defendant
`
`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 lacks knowledge or
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`5
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`information sufficient to form a belief as to the truth of the allegations, and therefore denies
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`them.
`
`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
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`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
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`the documents beyond the text of the document and distortions via selective excerpt
`
`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
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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.
`
`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
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`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,
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`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.
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`6
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`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 admits that the referenced documents About Velocity and Gaming and
`
`Enthusiast Laptops are copies of webpages from the website http://www.velocitymicro.com and
`
`state that it is “100% based in the USA in Richmond, VA,” and that some computers are
`
`“[a]ssembled by our expert engineers in Richmond, VA.” Defendant admits that the referenced
`
`document Configure Your M17 includes the text “Careful custom integration and testing, final
`
`assembly by hand in Richmond, Virginia, USA” under the section “Support.” Defendant
`
`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
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`Commonwealth of Virginia and appointed as its registered agent Freed & Shepherd, P.C., 9030
`
`Stony Point Pkwy Suite 400, Richmond, VA 23235, and denies any remaining allegations in this
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`paragraph.
`
`40.
`
`Defendant denies the allegations in this paragraph.
`
`ACCUSED PRODUCTS
`
`41.
`
`Defendant admits that the Amended Complaint defines the term “Accused
`
`Products” to include “Accused GPUs” and “Accused SOCs” and all products that contain an
`
`“Accused GPU” or “Accused SOC” that have been made, sold, or 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.
`
`42.
`
`Defendant admits that the Amended Complaint defines the term “Accused GPUs”
`
`to include “all NVIDIA GPUs and all products that contain a NVIDIA GPU that have been
`
`made, used, sold, offered for sale, or imported into the United States since November 4, 2008,
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`7
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`including the products identified in paragraphs 43 to 55.” Defendant denies that Defendant
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`infringes any valid and enforceable claim of the asserted patents.
`
`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
`
`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
`
`infringes any valid and enforceable claim of the asserted patents.
`
`44.
`
`The allegations in this paragraph contain subjective assessments from Plaintiffs
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`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.
`
`45.
`
`Defendant admits that the Amended Complaint defines the term “602 Accused
`
`GPUs” to include “all NVIDIA GPUs and all products that contain NVIDIA GPUs that are
`
`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
`
`that Defendant infringes any valid and enforceable claim of the asserted patents.
`
`46.
`
`The allegations in this paragraph contain 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.
`
`47.
`
`Defendant admits that the Amended Complaint defines the term “Accused 28 nm
`
`GPUs” to include “all NVIDIA GPUs utilizing 28 nanometer fabrication processing and all
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`8
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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.
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`48.
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`The allegations in this paragraph contain subjective assessments from Plaintiffs
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`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
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`them.
`
`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
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`nanometer, 80 nanometer, or 90 nanometer fabrication processing and all products that contain
`
`such a GPU.” Defendant denies that Defendant infringes any valid and enforceable claim of the
`
`asserted patents.
`
`50.
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`The allegations in this paragraph contain subjective assessments from Plaintiffs
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`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.
`
`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
`
`intended for use, in laptop computers.” Defendant denies that Defendant infringes any valid and
`
`enforceable claim of the asserted patents.
`
`52.
`
`The allegations in this paragraph contain subjective assessments from Plaintiffs
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`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.
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`9
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`53.
`
`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
`
`computers.” Defendant denies that Defendant infringes any valid and enforceable claim of the
`
`asserted patents.
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`54.
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`The allegations in this paragraph contain subjective assessments from Plaintiffs
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`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
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`them.
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`55.
`
`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
`
`contain such a GPU.” Defendant denies that Defendant infringes any valid and enforceable
`
`claim of the asserted patents.
`
`56.
`
`The allegations in this paragraph contain subjective assessments from Plaintiffs
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`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.
`
`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.
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`10
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`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.
`
`59.
`
`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.
`
`60.
`
`Defendant admits that the Amended Complaint defines the term “Accused 40 nm
`
`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.
`
`61.
`
`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.
`
`62.
`
`Defendant admits that the Amended Complaint defines the term “Cortex-A9
`
`SOCs” to include “all NVIDIA SOCs based on the ARM Cortex-A9 design and all products that
`
`contain such an SOC.” Defendant denies that Defendant infringes any valid and enforceable
`
`claim of the asserted patents.
`
`63.
`
`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.
`
`64.
`
`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
`
`that contain such an SOC.” Defendant denies that Defendant infringes any valid and enforceable
`
`claim of the asserted patents.
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`11
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`65.
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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.
`
`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.
`
`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.
`
`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.
`
`69.
`
`Defendant admits that the Amended Complaint defines the term “602 Accused
`
`Products” to include “602 Accused GPUs” and “Accused SOCs.” Defendant denies that
`
`Defendant infringes any valid and enforceable claim of the asserted patents.
`
`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.
`
`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
`
`hard drive with both a spinning platter and separate, solid-state non-volatile storage capacity—
`
`that have been made, used, sold, offered for sale, or imported into the United States at any time
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`12
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`since November 4, 2008.” Defendant denies that Defendant infringes any valid and enforceable
`
`claim of the asserted patents.
`
`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.
`
`73.
`
`Defendant admits that the Amended Complaint defines the term “724 Acussed
`
`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.
`
`74.
`
`Defendant admits that certain identified products may be a Velocity laptop
`
`computer that supports DisplayPort, depending on the context in which these terms are used.
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`This allegation relies on terms found in the claims of the ’724 patent and contains legal
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`arguments and conclusions; 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 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 enforceable claim
`
`of the ’724 patent.
`
`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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`13
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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.
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`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 admits that the document identified in this paragraph appears to be an
`
`accurate printout from the website http://www.velocitymicro.com. 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.
`
`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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`

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`Case 3:14-cv-00757-REP-DJN Document 61 Filed 03/03/15 Page 15 of 441 PageID# 5624
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`81.
`
`Defendant admits that the document identified in this paragraph appears to be an
`
`accurate printout from the website http://www.velocitymicro.com. 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.
`
`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 admits that the document identified in this paragraph appears to be an
`
`accurate printout from the website http://www.velocitymicro.com. 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.
`
`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 admits that the document identified in this paragraph appears to be an
`
`accurate printout from the website http://www.velocitymicro.com. 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.
`
`15
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`

`

`Case 3:14-cv-00757-REP-DJN Document 61 Filed 03/03/15 Page 16 of 441 PageID# 5625
`
`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
`
`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
`
`

`

`Case 3:14-cv-00757-REP-DJN Document 61 Filed 03/03/15 Page 17 of 441 PageID# 5626
`
`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 tru