Case 1:22-cv-22706-RNS Document 84 Entered on FLSD Docket 12/19/2022 Page 1 of 112
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF FLORIDA
`
`No. 1:22-cv-22706-RNS
`
`JURY TRIAL DEMANDED
`
`BELL NORTHERN RESEARCH, LLC,
`
`Plaintiff,
`
`v.
`
`HMD AMERICA, INC.; HMD GLOBAL OY;
`SHENZHEN CHINO-E COMMUNICATION
`CO., LTD.; HON HAI PRECISION
`INDUSTRY CO., LTD; TINNO MOBILE
`TECHNOLOGY CORP.; SHENZHEN TINNO
`MOBILE CO., LTD.; TINNO USA, INC.;
`UNISOC TECHNOLOGIES CO., LTD.;
`SPREADTRUM COMMUNICATIONS USA,
`INC.; WINGTECH TECHNOLOGY CO.,
`LTD.; WINGTECH INTERNATIONAL, INC.;
`HUAQIN CO., LTD; BEST BUY CO., INC.;
`BEST BUY STORES L.P.; TARGET CORP.;
`WALMART INC.,
`
`Defendants.
`
`ANSWER AND DEFENSES OF DEFENDANTS TINNO MOBILE TECHNOLOGY
`CORP., SHENZHEN TINNO MOBILE CO., LTD., AND TINNO USA, INC., TO
`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
`
`Defendants Tinno Mobile Technology Corp., Shenzhen Tinno Mobile Co., Ltd., and Tinno
`
`USA, Inc. (collectively, “Tinno” or “Defendants”) hereby answer the Complaint of Plaintiff Bell
`
`Northern Research, LLC (“BNR” or “Plaintiff”). To the extent not explicitly admitted, Defendants
`
`deny all allegations of the Complaint. Defendants deny that BNR is entitled to the relief requested
`
`or any other relief.
`
`NATURE OF THE ACTION
`
`This is an action for patent infringement arising under the Patent Laws of the United
`1.
`States, 35 U.S.C. § 1 et seq.
`
`-1-
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`

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`Case 1:22-cv-22706-RNS Document 84 Entered on FLSD Docket 12/19/2022 Page 2 of 112
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`ANSWER TO PARA. 1.
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`This paragraph states legal conclusions and allegations to which no
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`answer is required. To the extent an answer is required, Defendants admit that Plaintiff purports
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`to bring an action for patent infringement under the Patent Laws of the United States, but deny
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`that they have committed any act that would give rise to any cause of action. Defendants deny
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`any remaining allegations in this paragraph.
`
`THE PARTIES
`
`Plaintiff BNR is a limited liability company organized under the laws of the State
`2.
`of Delaware with a place of business at 401 North Michigan Avenue, Chicago, Illinois 60611.
`
`ANSWER TO PARA. 2.
`
`Defendants lack sufficient knowledge or information to either admit
`
`or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`Upon information and belief, Defendant HMD America, Inc. is a corporation
`3.
`organized and existing under the laws of the State of Florida, with its principal place of business
`at 1200 Brickell Ave., Suite. 510, Miami, Florida 33131. Upon information and belief, Defendant
`sells and offers to sell products and services throughout the United States, including in this judicial
`district, and introduces products and services that into the stream of commerce and that incorporate
`infringing technology knowing that they would be sold in this judicial district and elsewhere in the
`United States.
`
`ANSWER TO PARA. 3.
`
`Defendants deny that Plaintiff has alleged infringement of any valid
`
`and asserted patent claim. Defendants lack sufficient knowledge or information to either admit
`
`or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`Upon information and belief, Defendant HMD Global Oy is a corporation
`4.
`organized and existing under the laws of Finland, with its principal place of business at Bertel
`Jungin aukio 9, 02600 Espoo, Finland. Upon information and belief, Defendant sells and offers to
`sell products and services throughout the United States, including in this judicial district, and
`introduces products and services into the stream of commerce that incorporate infringing
`technology, knowing that they would be sold in this judicial district and elsewhere in the United
`States.
`
`ANSWER TO PARA. 4.
`
`Defendants deny that Plaintiff has alleged infringement of any valid
`
`and asserted patent claim. Defendants lack sufficient knowledge or information to either admit
`
`or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`-2-
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`Case 1:22-cv-22706-RNS Document 84 Entered on FLSD Docket 12/19/2022 Page 3 of 112
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`Upon information and belief, Defendant Shenzhen Chino-E Communication Co.,
`5.
`Ltd.is a corporation organized and existing under the laws of China, with its principal place of
`business at 139 Lixiang Road, Songmushan Dalang Town, Dongguan, 523770, China. Upon
`information and belief, Defendant sells and offers to sell products and services throughout the
`United States, including in this judicial district, and introduces products and services into the
`stream of commerce that incorporate infringing technology, knowing that they would be sold in
`this judicial district and elsewhere in the United States.
`
`ANSWER TO PARA. 5.
`
` Defendants deny that Plaintiff has alleged infringement of any valid
`
`and asserted patent claim. Defendants lack sufficient knowledge or information to either admit
`
`or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`Upon information and belief, Defendant Hon Hai Precision Industry Co., Ltd. is a
`6.
`corporation organized and existing under the laws of China, with its principal place of business at
`No.2, Ziyou St., Tucheng Dist., New Taipei City 236, Taiwan. Upon information and belief,
`Defendant sells and offers to sell products and services throughout the United States, including in
`this judicial district, and introduces products and services into the stream of commerce that
`incorporate infringing technology, knowing that they would be sold in this judicial district and
`elsewhere in the United States.
`
`ANSWER TO PARA. 6.
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`Defendants deny that Plaintiff has alleged infringement of any valid
`
`and asserted patent claim. Defendants lack sufficient knowledge or information to either admit
`
`or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`Upon information and belief, Defendant Tinno Mobile Technology Corp. is a
`7.
`corporation organized and existing under the laws of China, with its principal place of business at
`23/F, TINNO Building, No.33, Xiandong Rd, Xili, Nanshan District, Shenzhen, China. Upon
`information and belief, Defendant sells and offers to sell products and services throughout the
`United States, including in this judicial district, and introduces products and services into the
`stream of commerce that incorporate infringing technology, knowing that they would be sold in
`this judicial district and elsewhere in the United States.
`
`ANSWER TO PARA. 7.
`
` Tinno denies that any entity with the name “Tinno Mobile
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`Technology Corp.” exists, and therefore further denies the remaining allegations in this
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`paragraph. To the extent that this paragraph may be read to apply to any existing Tinno entity,
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`Tinno denies that it has engaged in allegedly infringing acts. Tinno denies the remaining
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`allegations of this paragraph.
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`-3-
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`

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`Case 1:22-cv-22706-RNS Document 84 Entered on FLSD Docket 12/19/2022 Page 4 of 112
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`Upon information and belief, Defendant Shenzhen Tinno Mobile Co., Ltd. is a
`8.
`corporation organized and existing under the laws of China, with its principal place of business at
`23/F, TINNO Building, No.33, Xiandong Rd, Xili, Nanshan District, Shenzhen, China. Upon
`information and belief, Defendant sells and offers to sell products and services throughout the
`United States, including in this judicial district, and introduces products and services into the
`stream of commerce that incorporate infringing technology, knowing that they would be sold in
`this judicial district and elsewhere in the United States.
`
`ANSWER TO PARA. 8.
`
`Tinno denies that any entity with the name “Shenzhen Tinno Mobile
`
`Co., Ltd.” exists, and therefore further denies the remaining allegations in this paragraph. To
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`the extent that this paragraph may be read to apply to any existing Tinno entity, Tinno denies
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`that it has engaged in allegedly infringing acts. Tinno denies the remaining allegations of this
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`paragraph.
`
`Upon information and belief, Defendant Tinno USA, Inc. is a corporation organized
`9.
`and existing under the laws of the State of Delaware, with its principal place of business at 2301
`W. Plano Parkway, Suite 102, Plano, Texas, 75075. Upon information and belief, Tinno USA, Inc.
`is a wholly owned subsidiary of Tinno Mobile Technology Corp. Upon information and belief,
`Defendant sells and offers to sell products and services throughout the United States, including in
`this judicial district, and introduces products and services into the stream of commerce that
`incorporate infringing technology, knowing that they would be sold in this judicial district and
`elsewhere in the United States.
`
`ANSWER TO PARA. 9.
`
`Tinno admits that Tinno USA, Inc. is organized and existing under
`
`the laws of the state of Delaware, and that it has a place of business at 2301 W. Plano Parkway,
`
`Suite 102, Plano, Texas, 75075. Tinno denies that it has engaged in allegedly infringing acts.
`
`Tinno denies the remaining allegations of this paragraph.
`
`Upon information and belief, Defendant Unisoc Technologies Co., Ltd. is a
`10.
`corporation organized and existing under the laws of China with its principal place of business at
`Building 1, Zhanxun Center, Lane 2288, Zuchongzhi Road, Pudong New Area, Shanghai, 201203,
`China. Upon information and belief, Defendant sells and offers to sell products and services
`throughout the United States, including in this judicial district, and introduces products and
`services into the stream of commerce that incorporate infringing technology, knowing that they
`would be sold in this judicial district and elsewhere in the United States.
`
`-4-
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`Case 1:22-cv-22706-RNS Document 84 Entered on FLSD Docket 12/19/2022 Page 5 of 112
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`ANSWER TO PARA. 10. Defendants deny that Plaintiff has alleged infringement of any valid
`
`and asserted patent claim. Defendants lack sufficient knowledge or information to either admit
`
`or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`Upon information and belief, Defendant Spreadtrum Communications USA Inc. is
`11.
`a corporation organized and existing under the laws of the State of Delaware with its principal
`place of business at 2674 N 1st St., San Jose, California, 95134. Upon information and belief,
`Defendant sells and offers to sell products and services throughout the United States, including in
`this judicial district, and introduces products and services into the stream of commerce that
`incorporate infringing technology, knowing that they would be sold in this judicial district and
`elsewhere in the United States.
`
`ANSWER TO PARA. 11. Defendants deny that Plaintiff has alleged infringement of any valid
`
`and asserted patent claim. Defendants lack sufficient knowledge or information to either admit
`
`or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`Upon information and belief, Defendant Wingtech Technology Co., Ltd. is a
`12.
`corporation organized and existing under the laws of China, with its principal place of business at
`No. 777, Subcentral Road, Nanhu District, Jiaxing, Zhejiang Province, China. Upon information
`and belief, Defendant sells and offers to sell products and services throughout the United States,
`including in this judicial district, and introduces products and services into the stream of commerce
`that incorporate infringing technology, knowing that they would be sold in this judicial district and
`elsewhere in the United States.
`
`ANSWER TO PARA. 12. Defendants deny that Plaintiff has alleged infringement of any valid
`
`and asserted patent claim. Defendants lack sufficient knowledge or information to either admit
`
`or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`Upon information and belief, Defendant Wingtech International, Inc. is a
`13.
`corporation organized and existing under the laws of the State of California, with its principal place
`of business at 21900 Oakview Ln., Cupertino, California, 95014. Upon information and belief,
`Defendant sells and offers to sell products and services throughout the United States, including in
`this judicial district, and introduces products and services into the stream of commerce that
`incorporate infringing technology, knowing that they would be sold in this judicial district and
`elsewhere in the United States.
`
`ANSWER TO PARA. 13.
`
` Tinno denies that Plaintiff has alleged infringement of any valid and
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`asserted patent claim. Tinno lacks sufficient knowledge or information to either admit or deny
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`the allegations in this paragraph of the Complaint, and therefore deny them.
`
`-5-
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`

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`Case 1:22-cv-22706-RNS Document 84 Entered on FLSD Docket 12/19/2022 Page 6 of 112
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`Upon information and belief, Defendant Huaqin Co. Ltd. is a corporation organized
`14.
`and existing under the laws of China, with its principal place of business at Building 1 & 9 & 11,
`NO.399 Keyuan Road, Zhangjiang Hi-Tech Park, Pudong New District, Shanghai, China. Upon
`information and belief, Defendant sells and offers to sell products and services throughout the
`United States, including in this judicial district, and introduces products and services into the
`stream of commerce that incorporate infringing technology, knowing that they would be sold in
`this judicial district and elsewhere in the United States.
`
`ANSWER TO PARA. 14. Defendants deny that Plaintiff has alleged infringement of any valid
`
`and asserted patent claim. Defendants lack sufficient knowledge or information to either admit
`
`or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`Upon information and belief, Defendant Best Buy Co., Inc. is a corporation
`15.
`organized and existing under the laws of the State of Minnesota, with its principal place of business
`at 7601 Penn Ave. S., Richfield, Minnesota, 55423. Upon information and belief, Defendant sells
`and offers to sell products and services throughout the United States, including in this judicial
`district, and introduces products and services into the stream of commerce that incorporate
`infringing technology, knowing that they would be sold in this judicial district and elsewhere in
`the United States.
`
`ANSWER TO PARA. 15. Defendants deny that Plaintiff has alleged infringement of any valid
`
`and asserted patent claim. Defendants lack sufficient knowledge or information to either admit
`
`or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`Upon information and belief, Defendant Best Buy Stores L.P. is a corporation
`16.
`organized and existing under the laws of the State of Delaware, with its principal place of business
`at 7601 Penn Ave. S., Richfield, Minnesota, 55423. Upon information and belief, Defendant sells
`and offers to sell products and services throughout the United States, including in this judicial
`district, and introduces products and services into the stream of commerce that incorporate
`infringing technology, knowing that they would be sold in this judicial district and elsewhere in
`the United States.
`
`ANSWER TO PARA. 16. Defendants deny that Plaintiff has alleged infringement of any valid
`
`and asserted patent claim. Defendants lack sufficient knowledge or information to either admit
`
`or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`Upon information and belief, Defendant Target Corp. is a corporation organized
`17.
`and existing under the laws of the State of Minnesota, with its principal place of business at 33
`South 6th St., Minneapolis, Minnesota, 55402. Upon information and belief, Defendant sells and
`offers to sell products and services throughout the United States, including in this judicial district,
`and introduces products and services into the stream of commerce that incorporate infringing
`
`-6-
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`Case 1:22-cv-22706-RNS Document 84 Entered on FLSD Docket 12/19/2022 Page 7 of 112
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`technology, knowing that they would be sold in this judicial district and elsewhere in the United
`States.
`
`ANSWER TO PARA. 17. Defendants deny that Plaintiff has alleged infringement of any valid
`
`and asserted patent claim. Defendants lack sufficient knowledge or information to either admit
`
`or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`Upon information and belief, Defendant Walmart Inc. is a corporation organized
`18.
`and existing under the laws of the State of Delaware, with its principal place of business at 702
`SW 8th St., Bentonville, Arkansas, 72716. Upon information and belief, Defendant sells and offers
`to sell products and services throughout the United States, including in this judicial district, and
`introduces products and services into the stream of commerce that incorporate infringing
`technology, knowing that they would be sold in this judicial district and elsewhere in the United
`States.
`
`ANSWER TO PARA. 18. Defendants deny that Plaintiff has alleged infringement of any valid
`
`and asserted patent claim. Defendants lack sufficient knowledge or information to either admit
`
`or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`JURISDICTION AND VENUE
`
`This is an action for patent infringement arising under the Patent Laws of the United
`19.
`States, Title 35 of the United States Code.
`
`ANSWER TO PARA. 19. This paragraph states legal conclusions and allegations to which no
`
`answer is required. To the extent an answer is required, Defendants admit that the Complaint
`
`purports to initiate an action for patent infringement under the Patent Laws of the United States
`
`of America, contained in Title 35 of the United States Code, but deny that they have committed
`
`any act that would give rise to any cause of action in the Complaint. Defendants deny any
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`remaining allegations in this paragraph.
`
`20.
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`This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
`
`ANSWER TO PARA. 20. Defendants admit that this Court has jurisdiction over claims for
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`patent infringement but lack sufficient knowledge or information to either admit or deny that
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`BNR has standing to bring its claims and therefore deny that BNR has standing and deny that
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`they have committed any act that would give rise to any cause of action in the Complaint.
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`Defendants deny any remaining allegations in this paragraph.
`
`21.
`
`Venue is proper in this judicial district under 28 U.S.C. § 1400(b).
`
`ANSWER TO PARA. 21. This paragraph states legal conclusions to which no answer is
`
`required. Defendants deny that Plaintiff has alleged infringement of any valid and asserted
`
`patent claim. Defendants lack sufficient knowledge or information to either admit or deny the
`
`allegations in this paragraph of the Complaint, and therefore deny them.
`
`Upon information and belief, Defendant HMD Global Oy is not a resident in the
`22.
`United States and may be sued in any judicial district. Defendant HMD America, Inc. has
`committed acts of infringement in this District and has a regular and established place of business
`in this District at 1200 Brickell Ave., Suite. 510, Miami, Florida 33131 and is incorporated in
`Florida.
`
`ANSWER TO PARA. 22. This paragraph states legal conclusions and allegations to which no
`
`answer is required. To the extent an answer is required, Defendants lack sufficient knowledge
`
`or information to either admit or deny the allegations in this paragraph of the Complaint, and
`
`therefore deny them. Defendants further deny that Plaintiff has alleged infringement of any
`
`valid and asserted patent claim.
`
`Upon information and belief, Defendant Chino-E is not a resident in the United
`23.
`States and may be sued in any judicial district. Defendant has committed acts of infringement in
`this District and has a regular and established place of business within this District.
`
`ANSWER TO PARA. 23. This paragraph states legal conclusions and allegations to which no
`
`answer is required. To the extent an answer is required, Defendants lack sufficient knowledge
`
`or information to either admit or deny the allegations in this paragraph of the Complaint, and
`
`therefore deny them. Defendants further deny that Plaintiff has alleged infringement of any
`
`valid and asserted patent claim.
`
`Upon information and belief, Defendant Hon Hai is not a resident in the United
`24.
`States and may be sued in any judicial district. Defendant has committed acts of infringement in
`this District and has a regular and established place of business within this District.
`
`-8-
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`ANSWER TO PARA. 24. This paragraph states legal conclusions and allegations to which no
`
`answer is required. To the extent an answer is required, Defendants lack sufficient knowledge
`
`or information to either admit or deny the allegations in this paragraph of the Complaint, and
`
`therefore deny them. Defendants further deny that Plaintiff has alleged infringement of any
`
`valid and asserted patent claim.
`
`Upon information and belief, Defendants Tinno Mobile Technology Corp. and
`25.
`Shenzhen Tinno Mobile Co., Ltd. are not residents in the United States and may be sued in any
`judicial district. Upon information and belief, Defendant Tinno USA, Inc. has a principal place of
`business at 2301 W. Plano Parkway, Suite 102, Plano, Texas, 75075, a testing site in Miami,
`Florida, in this District, and is registered for service of process at 7901 4th St. N., Ste. 300, St.
`Petersburg, Florida, 33702. Defendants have committed acts of infringement in this District and
`have a regular and established place of business within this District.
`
`ANSWER TO PARA. 25. This paragraph states legal conclusions and allegations to which no
`
`answer is required. To the extent an answer is required, Tinno denies that any entities with the
`
`name “Tinno Mobile Technology Corp.” or “Shenzhen Tinno Mobile Co., Ltd.” exist, and
`
`therefore deny each allegation of this paragraph to the extent they pertain to those non-existent
`
`entities. Tinno admits that Tinno USA, Inc. has a principal place of business at 2301 W. Plano
`
`Parkway, Suite 102, Plano, Texas, 75075 and is registered for service of process at 7901 4th
`
`St. N., Ste. 300, St. Petersburg, Florida, 33702. Defendants lack sufficient knowledge or
`
`information to either admit or deny the remaining allegations in this paragraph of the
`
`Complaint, and therefore deny them.
`
`Upon information and belief, Defendant Unisoc Technologies Co., Ltd. is not a
`26.
`resident in the United States and may be sued in any judicial district. Defendant has committed
`acts of infringement in this District and has a regular and established place of business within this
`District.
`
`ANSWER TO PARA. 26. This paragraph states legal conclusions and allegations to which no
`
`answer is required. To the extent an answer is required, Defendants lack sufficient knowledge
`
`or information to either admit or deny the allegations in this paragraph of the Complaint, and
`
`-9-
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`therefore deny them. Defendants further deny that Plaintiff has alleged infringement of any
`
`valid and asserted patent claim.
`
`Upon information and belief, Defendant Spreadtrum Communications USA Inc.
`27.
`(“Spreadtrum”) is wholly owned by Unisoc Technologies Co., Ltd., and has committed acts of
`infringement in this District and has a regular and established place of business within this District.
`
`ANSWER TO PARA. 27. This paragraph states legal conclusions and allegations to which no
`
`answer is required. To the extent an answer is required, Defendants lack sufficient knowledge
`
`or information to either admit or deny the allegations in this paragraph of the Complaint, and
`
`therefore deny them. Defendants further deny that Plaintiff has alleged infringement of any
`
`valid and asserted patent claim.
`
`Upon information and belief, Defendant Wingtech Technology Co., Ltd. is not a
`28.
`resident in the United States and may be sued in any judicial district. Defendant has committed
`acts of infringement in this District and has a regular and established place of business within this
`District.
`
`ANSWER TO PARA. 28. This paragraph states legal conclusions and allegations to which no
`
`answer is required. To the extent an answer is required, Defendants lack sufficient knowledge
`
`or information to either admit or deny the allegations in this paragraph of the Complaint, and
`
`therefore deny them. Defendants further deny that Plaintiff has alleged infringement of any
`
`valid and asserted patent claim.
`
`Upon information and belief, Wingtech International, Inc. is wholly owned by
`29.
`Wingtech Technology Co., Ltd., and has committed acts of infringement in this District and has a
`regular and established place of business within this District.
`
`ANSWER TO PARA. 29. This paragraph states legal conclusions and allegations to which no
`
`answer is required. To the extent an answer is required, Defendants lack sufficient knowledge
`
`or information to either admit or deny the allegations in this paragraph of the Complaint, and
`
`therefore deny them. Defendants further deny that Plaintiff has alleged infringement of any
`
`valid and asserted patent claim.
`
`-10-
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`Upon information and belief, Defendant Huaqin is not a resident in the United
`30.
`States and may be sued in any judicial district. Defendant has committed acts of infringement in
`this District and has a regular and established place of business within this District.
`
`ANSWER TO PARA. 30. This paragraph states legal conclusions and allegations to which no
`
`answer is required. To the extent an answer is required, Defendants lack sufficient knowledge
`
`or information to either admit or deny the allegations in this paragraph of the Complaint, and
`
`therefore deny them. Defendants further deny that Plaintiff has alleged infringement of any
`
`valid and asserted patent claim.
`
`Upon information and belief, Defendant Best Buy Co., Inc. has committed acts of
`31.
`infringement in this District (including, but not limited to, offers for sale of the Accused
`Instrumentalities via Bestbuy.com and its physical locations) and, on information and belief, actual
`sales of the Accused Instrumentalities at its physical locations, and has a regular and established
`place of business in this District, for example, at 10760 NW 17th St., Miami, Florida 33172.
`
`ANSWER TO PARA. 31. This paragraph states legal conclusions and allegations to which no
`
`answer is required. To the extent an answer is required, Defendants lack sufficient knowledge
`
`or information to either admit or deny the allegations in this paragraph of the Complaint, and
`
`therefore deny them. Defendants further deny that Plaintiff has alleged infringement of any
`
`valid and asserted patent claim.
`
`Upon information and belief, Defendant Best Buy Stores L.P. has committed acts
`32.
`of infringement in this District (including, but not limited to, offers for sale of the Accused
`Instrumentalities via Bestbuy.com and its physical locations) and, on information and belief, actual
`sales of the Accused Instrumentalities at its physical locations), and has a regular and established
`place of business in this District, for example, at 10760 NW 17th St., Miami, Florida 33172.
`
`ANSWER TO PARA. 32. This paragraph states legal conclusions and allegations to which no
`
`answer is required. To the extent an answer is required, Defendants lack sufficient knowledge
`
`or information to either admit or deny the allegations in this paragraph of the Complaint, and
`
`therefore deny them. Defendants further deny that Plaintiff has alleged infringement of any
`
`valid and asserted patent claim.
`
`-11-
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`Upon information and belief, Defendant Target has committed acts of infringement
`33.
`in this District (including, but not limited to, offers for sale of the Accused Instrumentalities via
`Target.com and its physical locations) and, on information and belief, actual sales of the Accused
`Instrumentalities at its physical locations, and has a regular and established place of business in
`this District, for example, at 10101 W. Flagler St., Miami, Florida 33174.
`
`ANSWER TO PARA. 33. This paragraph states legal conclusions and allegations to which no
`
`answer is required. To the extent an answer is required, Defendants lack sufficient knowledge
`
`or information to either admit or deny the allegations in this paragraph of the Complaint, and
`
`therefore deny them. Defendants further deny that Plaintiff has alleged infringement of any
`
`valid and asserted patent claim.
`
`Upon information and belief, Defendant Walmart has committed acts of
`34.
`infringement in this District (including, but not limited to, offers for sale of the Accused
`Instrumentalities via Walmart.com and its physical locations) and, on information and belief,
`actual sales of the Accused Instrumentalities at its physical locations, and has a regular and
`established place of business in this District, for example, at 9191 W. Flagler St., Miami, Florida
`33174.
`
`ANSWER TO PARA. 34. This paragraph states legal conclusions and allegations to which no
`
`answer is required. To the extent an answer is required, Defendants lack sufficient knowledge
`
`or information to either admit or deny the allegations in this paragraph of the Complaint, and
`
`therefore deny them. Defendants further deny that Plaintiff has alleged infringement of any
`
`valid and asserted patent claim.
`
`Upon information and belief, each Defendant is subject to this Court’s general and
`35.
`specific personal jurisdiction, because each Defendant has sufficient minimum contacts within the
`State of Florida and this District, pursuant to due process and/or the Florida Long Arm Statute,
`because each Defendant purposefully availed itself of the privileges of conducting business in the
`State of Florida and in this District, because each Defendant regularly conducts and solicits
`business within the State of Florida and within this District, and because Plaintiff’s causes of action
`arise directly from each of Defendants’ business contacts and other activities in the State of Florida
`and this District. Further, this Court has personal jurisdiction over Defendant HMD America, Inc.
`because it is incorporated in the State of Florida and has purposely availed itself of the privileges
`and benefits of the laws of the State of Florida.
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`ANSWER TO PARA. 35. Defendants state that they do not contest general and specific
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`personal jurisdiction for the limited purposes of this litigation only, and reserve the right to
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`Case 1:22-cv-22706-RNS Document 84 Entered on FLSD Docket 12/19/2022 Page 13 of 112
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`contest general and specific personal jurisdiction in any other litigation. To the extent this
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`paragraph is referring to Defendants other than Tinno, Tinno lacks knowledge or information
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`sufficient to form a belief about the truth of any and all allegations in this paragraph related to
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`Defendants other than Tinno, and, on that basis, denies any and all other allegations.
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`BACKGROUND
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`The Asserted Patents come from a rich pedigree dating back to the late 19th century.
`36.
`This is when Bell Labs sprang to life from the combined efforts of AT&T and Western Electric.
`Bell Labs is one of America’s greatest technology incubators, and paved the way for many
`technological advances we know and use today, including the transistor, several kinds of lasers,
`the UNIX operating system, and computer languages such as C++. In total, Bell Labs received
`nine Nobel Prizes for its work over the years.
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`ANSWER TO PARA. 36. Defendants lack sufficient knowledge or information to either admit
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`or deny the allegations in this paragraph of the Complaint, and therefore deny them.
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`Eventually the Bell system broke up and spawned several new companies. They
`37.
`included telecommunications powerhouses Lucent and Agere Systems. Lucent was absorbed by
`Nokia, while Agere Systems was acquired by LSI, then Avago, and ultimately renamed Broadcom.
`The Bell system also spun off Northern Electric which led to the creation of a research lab known
`as BNR. This lab grew to host thousands of engineers in offices around the gl