Case 1:22-cv-22706-RNS Document 87 Entered on FLSD Docket 12/19/2022 Page 1 of 92
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF FLORIDA
`NO. 1:22-cv-22706-RNS
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`BELL NORTHERN RESEARCH, LLC,
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`Plaintiff
`
`v.
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`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.
`
`_______________________________________/
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`JURY TRIAL DEMANDED
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`
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`Defendants.
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`ANSWER AND DEFENSES OF DEFENDANTS HMD AMERICA, INC.; HMD GLOBAL
`OY; BEST BUY CO., INC.; BEST BUY STORES L.P.; TARGET CORP.; AND
`WALMART INC. TO PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
`
`
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`Defendants HMD America, Inc. (“HMD America”); HMD Global Oy (“HMD Global”
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`and, collectively with HMD America, “HMD”); Best Buy Co. Inc. and Best Buy Stores L.P.
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`(collectively, “Best Buy”); Target Corp. (“Target”); and Walmart Inc. (“Walmart”) (all
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`collectively, “Defendants”) hereby answer the Complaint of Plaintiff Bell Northern Research, LLC
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`(“Bell Northern”). To the extent not explicitly admitted, Defendants deny all allegations of the
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`Complaint. Defendants deny that Bell Northern is entitled to the relief requested or any other relief.
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`-1-
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`

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`Case 1:22-cv-22706-RNS Document 87 Entered on FLSD Docket 12/19/2022 Page 2 of 92
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`NATURE OF THE ACTION
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`1.
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`This is an action for patent infringement arising under the Patent Laws of the United States,
`35 U.S.C. § 1 et seq.
`
`ANSWER: This paragraph states legal conclusions and allegations to which no answer is
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`required. To the extent an answer is required, Defendants admit that Plaintiff purports to bring an
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`action for patent infringement under the Patent Laws of the United States. Defendants deny any
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`remaining allegations in this paragraph.
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`THE PARTIES
`
`2.
`
`Plaintiff BNR is a limited liability company organized under the laws of the State of
`Delaware with a place of business at 401 North Michigan Avenue, Chicago, Illinois 60611.
`
`ANSWER: Defendants lack sufficient knowledge or information to either admit or deny the
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`allegations in this paragraph of the Complaint, and therefore deny them.
`
`3.
`
`Upon information and belief, Defendant HMD America, Inc. is a corporation 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: HMD admits that HMD America is a corporation organized and existing under the
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`laws of the State of Florida, with its principal place of business at 1200 Brickell Ave., Suite. 510,
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`Miami, Florida 33131. HMD denies the remaining allegations in this paragraph. Best Buy, Target,
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`and Walmart lack sufficient knowledge or information to either admit or deny the allegations in
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`this paragraph of the Complaint, and therefore deny them.
`
`4.
`
`Upon information and belief, Defendant HMD Global Oy is a corporation 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.
`
`-2-
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`Case 1:22-cv-22706-RNS Document 87 Entered on FLSD Docket 12/19/2022 Page 3 of 92
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`ANSWER: HMD admits that HMD Global is a corporation organized and existing under the
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`laws of Finland, with its principal place of business at Bertel Jungin aukio 9, 02600 Espoo, Finland.
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`HMD denies the remaining allegations in this paragraph. Best Buy, Target, and Walmart lack
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`sufficient knowledge or information to either admit or deny the allegations in this paragraph of the
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`Complaint, and therefore deny them.
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`5.
`
`Upon information and belief, Defendant Shenzhen Chino-E Communication Co., 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: Defendants lack sufficient knowledge or information to either admit or deny the
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`allegations in this paragraph of the Complaint, and therefore deny them.
`
`6.
`
`Upon information and belief, Defendant Hon Hai Precision Industry Co., Ltd. is a
`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: Defendants lack sufficient knowledge or information to either admit or deny the
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`allegations in this paragraph of the Complaint, and therefore deny them.
`
`7.
`
`Upon information and belief, Defendant Tinno Mobile Technology Corp. is a 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: Defendants lack sufficient knowledge or information to either admit or deny the
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`allegations in this paragraph of the Complaint, and therefore deny them.
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`-3-
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`Case 1:22-cv-22706-RNS Document 87 Entered on FLSD Docket 12/19/2022 Page 4 of 92
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`8.
`
`Upon information and belief, Defendant Shenzhen Tinno Mobile Co., Ltd. is a 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: Defendants lack sufficient knowledge or information to either admit or deny the
`
`allegations in this paragraph of the Complaint, and therefore deny them.
`
`9.
`
`Upon information and belief, Defendant Tinno USA, Inc. is a corporation organized 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.
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`ANSWER: Defendants lack sufficient knowledge or information to either admit or deny the
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`allegations in this paragraph of the Complaint, and therefore deny them.
`
`10.
`
`Upon information and belief, Defendant Unisoc Technologies Co., Ltd. is a 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.
`
`ANSWER: Defendants lack sufficient knowledge or information to either admit or deny the
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`allegations in this paragraph of the Complaint, and therefore deny them.
`
`11.
`
`Upon information and belief, Defendant Spreadtrum Communications USA Inc. is 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.
`
`-4-
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`

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`Case 1:22-cv-22706-RNS Document 87 Entered on FLSD Docket 12/19/2022 Page 5 of 92
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`ANSWER: Defendants lack sufficient knowledge or information to either admit or deny the
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`allegations in this paragraph of the Complaint, and therefore deny them.
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`12.
`
`Upon information and belief, Defendant Wingtech Technology Co., Ltd. is a 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: Defendants lack sufficient knowledge or information to either admit or deny the
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`allegations in this paragraph of the Complaint, and therefore deny them.
`
`13.
`
`Upon information and belief, Defendant Wingtech International, Inc. is a 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: Defendants lack sufficient knowledge or information to either admit or deny the
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`allegations in this paragraph of the Complaint, and therefore deny them.
`
`14.
`
`Upon information and belief, Defendant Huaqin Co. Ltd. is a corporation organized 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: Defendants lack sufficient knowledge or information to either admit or deny the
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`allegations in this paragraph of the Complaint, and therefore deny them.
`
`15.
`
`Upon information and belief, Defendant Best Buy Co., Inc. is a corporation 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.
`
`-5-
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`

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`Case 1:22-cv-22706-RNS Document 87 Entered on FLSD Docket 12/19/2022 Page 6 of 92
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`ANSWER: Best Buy admits that Best Buy Co., Inc. is a corporation organized and existing
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`under the laws of the State of Minnesota, with a place of business at 7601 Penn Ave. S., Richfield,
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`Minnesota, 55423. Best Buy denies that Best Buy Co., Inc. is the proper party or Best Buy entity
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`to this lawsuit. Best Buy denies the remaining allegations in this paragraph. HMD, Target, and
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`Walmart lack sufficient knowledge or information to either admit or deny the allegations in this
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`paragraph of the Complaint, and therefore deny them.
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`16.
`
`Upon information and belief, Defendant Best Buy Stores L.P. is a corporation 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.
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`ANSWER: Best Buy admits that Best Buy Stores L.P. is a limited partnership organized and
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`existing under the laws of the State of Virginia, with a place of business at 7601 Penn Ave. S.,
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`Richfield, Minnesota, 55423. Best Buy denies the remaining allegations in this paragraph. HMD,
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`Target, and Walmart lack sufficient knowledge or information to either admit or deny the
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`allegations in this paragraph of the Complaint, and therefore deny them.
`
`17.
`
`Upon information and belief, Defendant Target Corp. is a corporation organized 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 technology, knowing that they would be sold in this judicial district
`and elsewhere in the United States.
`
`ANSWER: Target admits that it is a corporation organized and existing under the laws of the
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`State of Minnesota, with its principal place of business at 33 South 6th St., Minneapolis,
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`Minnesota, 55402. Target denies the remaining allegations in this paragraph. HMD, Best Buy, and
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`Walmart lack sufficient knowledge or information to either admit or deny the allegations in this
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`paragraph of the Complaint, and therefore deny them.
`
`-6-
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`Case 1:22-cv-22706-RNS Document 87 Entered on FLSD Docket 12/19/2022 Page 7 of 92
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`18.
`
`Upon information and belief, Defendant Walmart Inc. is a corporation organized 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: Walmart admits that it is a corporation organized and existing under the laws of the
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`State of Delaware, with its principal place of business at 702 SW 8th St., Bentonville, Arkansas,
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`72716. Walmart denies the remaining allegations in this paragraph. HMD, Best Buy, and Target
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`lack sufficient knowledge or information to either admit or deny the allegations in this paragraph
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`of the Complaint, and therefore deny them.
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`JURISDICTION AND VENUE
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`19.
`
`This is an action for patent infringement arising under the Patent Laws of the United States,
`Title 35 of the United States Code.
`
`ANSWER: 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
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`initiate an action for patent infringement under the Patent Laws of the United States of America,
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`contained in Title 35 of the United States Code, but deny they have committed any act that would
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`give rise to any cause of action in the Complaint. Otherwise, denied.
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`20.
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`This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
`
`ANSWER: Defendants admit that this Court has jurisdiction over claims for patent
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`infringement but deny that Bell Northern has standing to bring its claims and deny that Defendants
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`have committed any act that would give rise to any cause of action in the Complaint. Otherwise,
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`denied.
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`-7-
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`

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`Case 1:22-cv-22706-RNS Document 87 Entered on FLSD Docket 12/19/2022 Page 8 of 92
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`21.
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`Venue is proper in this judicial district under 28 U.S.C. § 1400(b).
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`ANSWER: This paragraph states legal conclusions to which no answer is required. To the
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`extent an answer is required, for purposes of this litigation only, HMD admits that venue would
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`be proper in this judicial district under 28 U.S.C. § 1400(b) solely with respect to HMD America.
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`HMD denies the remaining allegations in this paragraph. Best Buy, Target, and Walmart lack
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`sufficient knowledge or information to either admit or deny the allegations in this paragraph of the
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`Complaint, and therefore deny them.
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`22.
`
`Upon information and belief, Defendant HMD Global Oy is not a resident in the 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: This paragraph states legal conclusions and allegations to which no answer is
`
`required. To the extent an answer is required, HMD admits that HMD Global is not a resident in
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`the United States. HMD denies the remaining allegations in this paragraph. Best Buy, Target, and
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`Walmart lack sufficient knowledge or information to either admit or deny the allegations in this
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`paragraph of the Complaint, and therefore deny them.
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`23.
`
`Upon information and belief, Defendant Chino-E is not a 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: 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
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`to either admit or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`-8-
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`

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`24.
`
`Upon information and belief, Defendant Hon Hai is not a 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: 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
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`to either admit or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`25.
`
`Upon information and belief, Defendants Tinno Mobile Technology Corp. and 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: 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.
`
`26.
`
`Upon information and belief, Defendant Unisoc Technologies Co., Ltd. is not a 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: 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.
`
`27.
`
`Upon information and belief, Defendant Spreadtrum Communications USA Inc.
`(“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: 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
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`to either admit or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`-9-
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`

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`28.
`
`Upon information and belief, Defendant Wingtech Technology Co., Ltd. is not a 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: 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.
`
`29.
`
`Upon information and belief, Wingtech International, Inc. is wholly owned by 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: 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.
`
`30.
`
`Upon information and belief, Defendant Huaqin is not a 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: 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.
`
`31.
`
`Upon information and belief, Defendant Best Buy Co., Inc. has committed acts 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: This paragraph states legal conclusions and allegations to which no answer is
`
`required. To the extent an answer is required, Best Buy denies the allegations in this paragraph of
`
`the Complaint. HMD, Target, and Walmart lack sufficient knowledge or information to either
`
`admit or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`-10-
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`

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`32.
`
`Upon information and belief, Defendant Best Buy Stores L.P. has committed acts 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: This paragraph states legal conclusions and allegations to which no answer is
`
`required. To the extent an answer is required, Best Buy denies the allegations in this paragraph of
`
`the Complaint. HMD, Target, and Walmart lack sufficient knowledge or information to either
`
`admit or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`33.
`
`Upon information and belief, Defendant Target has committed acts of infringement 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: This paragraph states legal conclusions and allegations to which no answer is
`
`required. To the extent an answer is required, Target denies the allegations in this paragraph of the
`
`Complaint. HMD, Best Buy, and Walmart lack sufficient knowledge or information to either admit
`
`or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`34.
`
`Upon information and belief, Defendant Walmart has committed acts of 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: This paragraph states legal conclusions and allegations to which no answer is
`
`required. To the extent an answer is required, Walmart denies the allegations in this paragraph of
`
`the Complaint. HMD, Target, and Best Buy lack sufficient knowledge or information to either
`
`admit or deny the allegations in this paragraph of the Complaint, and therefore deny them.
`
`-11-
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`35.
`
`Upon information and belief, each Defendant is subject to this Court’s general and 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.
`
`ANSWER: This paragraph states legal conclusions and allegations to which no answer is
`
`required. To the extent an answer is required, for purposes of this litigation only, HMD will not
`
`contest personal jurisdiction with respect to HMD Global and HMD America. HMD denies the
`
`remaining allegations in this paragraph. Best Buy, Target, and Walmart lack sufficient knowledge
`
`or information to either admit or deny the allegations in this paragraph of the Complaint regarding
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`HMD, and therefore deny them, and deny the remaining allegations in this paragraph of the
`
`Complaint.
`
`BACKGROUND
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`36.
`
`The Asserted Patents come from a rich pedigree dating back to the late 19th century. 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.
`
`ANSWER: Defendants lack sufficient knowledge or information to either admit or deny the
`
`allegations in this paragraph of the Complaint, and therefore deny them.
`
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`

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`Case 1:22-cv-22706-RNS Document 87 Entered on FLSD Docket 12/19/2022 Page 13 of 92
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`37.
`
`Eventually the Bell system broke up and spawned several new companies. They 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 globe. One of those was an 800,000-square-foot campus in Richardson, Texas.
`
`ANSWER: Defendants lack sufficient knowledge or information to either admit or deny the
`
`allegations in this paragraph of the Complaint, and therefore deny them.
`
`38.
`
`Collectively, these companies spurred a digital revolution in telecommunications, starting
`with the first digital telephone switch in 1975. They continued to push the industry to new
`heights in the late-80s, when BNR announced the desire to create a global fiber optic
`network (called “FiberWorld”). Its goal was to give users easy, reliable, and fast access to
`a variety of multimedia services. To realize this vision, Bell Labs and subsequent
`innovators made numerous breakthroughs in laser, integrated circuit, photodetector,
`amplifier, and waveguide designs. These advancements led to the modern fiber optic
`systems we use today.
`
`ANSWER: Defendants lack sufficient knowledge or information to either admit or deny the
`
`allegations in this paragraph of the Complaint, and therefore deny them.
`
`39.
`
`This work naturally evolved to include cellular telecommunications as well. On May 6,
`1992, BNR VP George Brody—along with executives from Bell Cellular and Northern
`Electric—made the first Canada-US digital cellular call. It stretched from Toronto, Ontario
`to Fort Worth, Texas.
`
`ANSWER: Defendants lack sufficient knowledge or information to either admit or deny the
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`allegations in this paragraph of the Complaint, and therefore deny them.
`
`40.
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`Eventually, Nortel Networks absorbed BNR. A