`
`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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`)
`)
`)
`)
`)
`)
`)
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`
`DEFENDANT NVIDIA CORPORATION’S
`ANSWER AND COUNTERCLAIMS TO SECOND AMENDED COMPLAINT
`
`Defendant NVIDIA Corporation (“NVIDIA” or “Defendant”), by and through its
`
`undersigned attorneys, hereby file this Second Amended Answer to Plaintiffs Samsung
`
`Electronics Company, Ltd. (“SEC”) and Samsung Electronics America, Inc.’s (“SEA”)
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`(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
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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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`Case 3:14-cv-00757-REP-DJN Document 87 Filed 04/16/15 Page 2 of 1277 PageID# 12964
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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
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`SAMSUNG
`
`6.
`
`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`7.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`8.
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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.
`
`9.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`10.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`11.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`12.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`13.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`14.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`2
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`Case 3:14-cv-00757-REP-DJN Document 87 Filed 04/16/15 Page 3 of 1277 PageID# 12965
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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.
`
`16.
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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.
`
`NVIDIA
`
`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
`
`in this paragraph depends on context and the paragraph contains subjective assessments from
`
`Plaintiffs. Thus, Defendant lacks knowledge or information sufficient to form a belief as to the
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`truth or falsity of the remaining allegations contained in this paragraph and therefore denies
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`them.
`
`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.
`
`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.
`
`VELOCITY
`
`3
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`Case 3:14-cv-00757-REP-DJN Document 87 Filed 04/16/15 Page 4 of 1277 PageID# 12966
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`22.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`23.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`24.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`25.
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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.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`27.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`28.
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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.
`
`29.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`30.
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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.
`
`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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`Case 3:14-cv-00757-REP-DJN Document 87 Filed 04/16/15 Page 5 of 1277 PageID# 12967
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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.
`
`34.
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`35.
`
`Defendant denies the allegations in this paragraph.
`
`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.
`
`Defendant admits that it sells products nationwide, including in Virginia, and
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`denies all other allegations in this paragraph.
`
`37.
`
`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.
`
`38.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
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`39.
`
`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.
`
`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
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`“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. Defendant denies any
`
`remaining allegations.
`
`5
`
`
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`Case 3:14-cv-00757-REP-DJN Document 87 Filed 04/16/15 Page 6 of 1277 PageID# 12968
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`42.
`
`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
`
`made, used, sold, offered for sale, or imported into the United States since November 4, 2008,
`
`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
`
`remaining allegations.
`
`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
`
`posted CAS latency functionality or any equivalent thereof.” Defendant denies that Defendant
`
`infringes any valid and enforceable claim of the asserted patents. Defendant denies any
`
`remaining allegations.
`
`44.
`
`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
`
`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
`
`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
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`designed to support any SDRAM or SGRAM that includes an input data strobe feature
`
`supporting single-ended and differential signaling or any equivalent thereof.” Defendant denies
`
`6
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`Case 3:14-cv-00757-REP-DJN Document 87 Filed 04/16/15 Page 7 of 1277 PageID# 12969
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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.
`
`46.
`
`47.
`
`Defendant denies the allegations in this paragraph.
`
`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
`
`products that contain such a GPU.” Defendant denies that Defendant infringes any valid and
`
`enforceable claim of the asserted patents. Defendant denies any remaining allegations.
`
`48.
`
`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
`
`allegations set forth in this paragraph, and on that basis denies them.
`
`49.
`
`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
`
`such a GPU.” Defendant denies that Defendant infringes any valid and enforceable claim of the
`
`asserted patents. Defendant denies any remaining allegations.
`
`50.
`
`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
`
`7
`
`
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`Case 3:14-cv-00757-REP-DJN Document 87 Filed 04/16/15 Page 8 of 1277 PageID# 12970
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`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
`
`this paragraph, and on that basis denies them.
`
`51.
`
`Defendant admits that the Amended Complaint defines the term “’724 Accused
`
`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
`
`enforceable claim of the asserted patents. Defendant denies any remaining allegations.
`
`52.
`
`Defendant admits that certain identified products may contain an NVIDIA GPU
`
`that supports DisplayPort and can be used in a laptop computer, depending on the context in
`
`which these terms are used. This allegation relies on terms found in the claims of the ’724 patent
`
`and contains legal arguments and conclusions; therefore, no answer is required. This allegation
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`further seeks premature claim construction and/or expert discovery before the Court has opened
`
`discovery. 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.
`
`53.
`
`Defendant admits that the Amended Complaint defines the term “724 Accused
`
`Mobile GPUs with Analog Output” to include “all NVIDIA GPUs that support DisplayPort and
`
`an analog output, such as DVI or VGA, and that are intended for use or used in laptop
`
`8
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`Case 3:14-cv-00757-REP-DJN Document 87 Filed 04/16/15 Page 9 of 1277 PageID# 12971
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`computers.” Defendant denies that Defendant infringes any valid and enforceable claim of the
`
`asserted patents. Defendant denies any remaining allegations.
`
`54.
`
`Defendant admits that certain identified products may contain an NVIDIA GPU
`
`that supports DisplayPort, DVI and/or VGA, and that is used, or intended for use, in a laptop
`
`computer, depending on the context in which these terms are used. This allegation relies on
`
`terms found in the claims of the ’724 patent and contains legal arguments and conclusions;
`
`therefore, no answer is required. This allegation further seeks premature claim construction
`
`and/or expert discovery before the Court has opened discovery. 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.
`
`55.
`
`Defendant admits that the Amended Complaint defines the term “Unified Cache
`
`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. Defendant denies any remaining allegations.
`
`56.
`
`Defendant admits, based on its present understanding, certain identified products
`
`may be or may contain an NVIDIA GPU with a unified L2 cache, depending on the context in
`
`which these terms are used. Defendant further admits that certain of the identified products are
`
`9
`
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`Case 3:14-cv-00757-REP-DJN Document 87 Filed 04/16/15 Page 10 of 1277 PageID# 12972
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`based on the Fermi, Kepler, or Maxwell microarchitectures. This allegation relies on terms
`
`found in the claims of the ’158 patent and contains legal arguments and conclusions; therefore,
`
`no answer is required. This allegation further seeks premature claim construction and/or expert
`
`discovery before the Court has opened discovery. 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 ’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 not infringe any valid and enforceable claim
`
`of the ’158 patent.
`
`57.
`
`Defendant admits that the Amended Complaint defines the term “Accused SOCs”
`
`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
`
`10
`
`
`
`Case 3:14-cv-00757-REP-DJN Document 87 Filed 04/16/15 Page 11 of 1277 PageID# 12973
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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
`
`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.
`
`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. 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
`
`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
`
`contain such an SOC.” Defendant denies that Defendant infringes any valid and enforceable
`
`claim of the asserted patents. Defendant denies any remaining allegations.
`
`63.
`
`Defendant admits that depending on context, certain identified products may be
`
`based on the ARM Cortex-A9 design. This allegation is vague and ambiguous at least because
`
`11
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`Case 3:14-cv-00757-REP-DJN Document 87 Filed 04/16/15 Page 12 of 1277 PageID# 12974
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`Samsung has not explained what it means by “based on the ARM Cortex-A9 design.” This
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`allegation also relies on a third party document or relates to a third party product. Defendant
`
`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.
`
`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. Defendant denies any remaining allegations.
`
`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.” This
`
`allegation also relies on a third party document or relates to a third party product. 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.
`
`12
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`Case 3:14-cv-00757-REP-DJN Document 87 Filed 04/16/15 Page 13 of 1277 PageID# 12975
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`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
`
`Defendant infringes any valid and enforceable claim of the asserted patents. Defendant denies
`
`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
`
`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
`
`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
`
`13
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`Case 3:14-cv-00757-REP-DJN Document 87 Filed 04/16/15 Page 14 of 1277 PageID# 12976
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`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.
`
`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
`
`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.
`
`14
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`80.
`
`This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`81.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth within this paragraph, and on that basis denies them.
`
`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.
`
`15
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`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.
`
`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.
`
`16
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`93.
`
`This paragraph contains no factua