Case: 1:16-cv-04826 Document #: 27 Filed: 08/29/16 Page 1 of 60 PageID #:1166
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
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`T-REX PROPERTY AB,
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`Plaintiff,
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`v.
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`CONTEXTMEDIA, INC. AND
`CONTEXTMEDIA HEALTH, LLC,
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`Defendants.
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`Judge Joan H. Lefkow
`Magistrate Judge Maria Valdez
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`Civil Action No. 16-4826
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`Document electronically filed.
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`DEFENDANTS’ ANSWER, DEFENSES, AND COUNTERCLAIMS TO
`PLAINTIFF’S AMENDED COMPLAINT FOR PATENT INFRINGEMENT
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`Defendants ContextMedia, Inc. and ContextMedia Health, LLC (“ContextMedia”),
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`through their counsel, hereby sets forth their Answer, Defenses and Counterclaims to the
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`Amended Complaint filed by Plaintiff T-Rex Property AB (“Plaintiff” or “T-Rex”) as follows:
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`NATURE OF THE ACTION
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`This is an action for patent infringement arising under the patent laws of the
`1.
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`United States, 35 U.S.C. § 1 et seq., including 35 U.S.C. §§ 271, 281, 283, 284 and 285.
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`ANSWER:
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`ContextMedia admits that this is an action for patent infringement. ContextMedia denies
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`the merits of this action, and therefore, except as expressly admitted, denies all other allegations
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`set forth in paragraph 1 of the Amended Complaint.
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`PARTIES
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`Plaintiff T-Rex Property AB is a company organized and existing under the laws
`2.
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`of Sweden with its principal place of business at Vårvägen 6, 18274 Stocksund, Sweden.
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`ANSWER:
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`1
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`

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`Case: 1:16-cv-04826 Document #: 27 Filed: 08/29/16 Page 2 of 60 PageID #:1167
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`ContextMedia is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations contained in paragraph 2 of the Amended Complaint, and, accordingly,
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`denies the allegations set forth in paragraph 2 of the Amended Complaint.
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`On information and belief, Defendant ContextMedia, Inc., is an Illinois
`3.
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`corporation with an office located at 330 N. Wabash Ave., Suite 2500, Chicago, Illinois.
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`ANSWER:
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`Admitted.
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`On information and belief, Defendant ContextMedia Health, LLC, is a Delaware
`4.
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`limited liability corporation with a principal office located at 330 N. Wabash Ave., Suite 2500,
`Chicago, Illinois. On information and belief, Defendant’s registered agent is Corporation
`Service Company, 2711 Centerville Rd, Suite 400, Wilmington, Delaware 19808.
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`ANSWER:
`
`Admitted.
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`JURISDICTION AND VENUE
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`This Court has subject matter jurisdiction over this patent infringement action
`5.
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`under 28 U.S.C. §§ 1331 and 1338(a).
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`ANSWER:
`
`Admitted.
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`This Court has personal jurisdiction over Defendant ContextMedia, Inc., because,
`6.
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`on information and belief, Defendant has systematic and continuous contacts with Illinois and
`this judicial district because Defendant has an office located in this judicial district, it regularly
`transacts business in the State of Illinois and this judicial district and it has thereby purposefully
`availed itself of the benefits and protections of the laws of the State of Illinois. Furthermore, this
`Court has personal jurisdiction over Defendant because, as described further below, Defendant
`has committed acts of patent infringement giving rise to this action within the State of Illinois
`and has thus established minimum contacts such that the exercise of personal jurisdiction over
`Defendant does not offend traditional notions of fair play and substantial justice.
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`ANSWER:
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`2
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`Case: 1:16-cv-04826 Document #: 27 Filed: 08/29/16 Page 3 of 60 PageID #:1168
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`ContextMedia, Inc. admits that it is subject to personal jurisdiction in this District for this
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`particular action. Except as expressly admitted, ContextMedia denies all other allegations set
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`forth in paragraph 6 of the Amended Complaint.
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`This Court has personal jurisdiction over Defendant ContextMedia Health, LLC,
`7.
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`because, on information and belief, Defendant has systematic and continuous contacts with
`Illinois and this judicial district because Defendant has an office located in this judicial district, it
`regularly transacts business in the State of Illinois and this judicial district and it has thereby
`purposefully availed itself of the benefits and protections of the laws of the State of Illinois.
`Furthermore, this Court has personal jurisdiction over Defendant because, as described further
`below, Defendant has committed acts of patent infringement giving rise to this action within the
`State of Illinois and has thus established minimum contacts such that the exercise of personal
`jurisdiction over Defendant does not offend traditional notions of fair play and substantial
`justice.
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`ANSWER:
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`ContextMedia Health, LLC admits that it is subject to personal jurisdiction in this District
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`for this particular action. Except as expressly admitted, ContextMedia denies all other
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`allegations set forth in paragraph 7 of the Amended Complaint.
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`Venue is proper in this Judicial District under 28 U.S.C. §§ 1391 and 1400(b).
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`8.
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`ANSWER:
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`ContextMedia admits that venue is technically proper in this District under 28 U.S.C. §§
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`1391 and 1400(b). ContextMedia denies the remaining allegations set forth in paragraph 8 of the
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`Amended Complaint.
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`THE PATENTS-IN-SUIT
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`The allegations set forth in the foregoing paragraphs 1 through 8 are hereby
`9.
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`realleged and incorporated herein by reference.
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`ANSWER:
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`ContextMedia incorporates by reference its responses to the preceding allegations of
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`paragraphs 1 through 8 above as though stated herein.
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`3
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`Case: 1:16-cv-04826 Document #: 27 Filed: 08/29/16 Page 4 of 60 PageID #:1169
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`The ‘470 Patent
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`On January 16, 2007, U.S. Patent Number RE39,470 (the “’470 Patent”), entitled
`10.
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`“Digital Information System,” was duly and legally issued by the United States Patent and
`Trademark Office. A true and correct copy of the ’470 Patent is attached as Exhibit A to this
`Amended Complaint.
`
`ANSWER:
`
`ContextMedia admits that on January 16, 2007, U.S. Patent Number RE39,470, entitled
`
`“Digital Information System,” was issued by the United States Patent and Trademark Office.
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`ContextMedia admits that Exhibit A attached to the Amended Complaint purports to be a copy
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`of the ‘470 Patent. ContextMedia denies the allegations in paragraph 10 insofar as they allege
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`that the ‘470 Patent was duly and legally issued. ContextMedia is without sufficient information
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`or knowledge to form a belief as to the truth of the remaining allegations set forth in paragraph
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`10 of the Amended Complaint, and, accordingly, denies the allegations.
`
`The ’470 Patent is a reissue of U.S. Patent Number 6,005,534, which was filed on
`11.
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`July 2, 1996 and which claims priority under 35 U.S.C. § 119(e) to U.S. Provisional Patent
`Application Number 60/017,403, which was filed on May 14, 1996. The ’534 Patent also claims
`priority under 35 U.S.C. § 119(a)-(d) to foreign patent application number 9601603-5, which
`was filed on April 26, 1996 in Sweden. As “[p]riority under section 119, 365(a), 365(b), 386(a),
`or 386(b) shall not be taken into account in determining the term of a patent,” (35 U.S.C. §
`154(a)(3)), the ’470 Patent expires 20 years from July 2, 1996.
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`ANSWER:
`
`ContextMedia admits that the face of the ‘470 Patent indicates that it is a reissue of U.S.
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`Patent Number 6,005,534, and that the face of U.S. Patent Number 6,005,534 indicates that it
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`was filed on July 2, 1996 and claims priority to U.S. Provisional Patent Application Number
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`60/017,403. ContextMedia admits that the face of the ‘534 Patent indicates that it also claims
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`priority to foreign patent application number 9601603-5. ContextMedia admits that the ‘470
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`Patent expired 20 years from July 2, 1996. ContextMedia denies the allegations in paragraph 11
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`insofar as they allege that the ‘470 Patent, ‘534 Patent, or foreign patent application number
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`4
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`9601603-5 disclose or claim patentable inventions. ContextMedia is without sufficient
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`information or knowledge to form a belief as to the truth of the remaining allegations set forth in
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`paragraph 11 of the Amended Complaint, and, accordingly, denies the allegations.
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`The innovations disclosed in the ’470 Patent “relate[] to a method and apparatus
`12.
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`for controlling and coordinating” electronic displays “in a digital information system for
`displaying information on at least one display device . . . said information being displayed in
`places that are accessible to and frequented by a general public.” (’470 Patent at 1:15-21.) “An
`object of the present invention is to provide a flexible system in which external information
`mediators are able to dynamically control in real time the transmission of display instructions to
`a larger public in different places” “and to enable similar or specific information to be displayed
`in places that are mutually far apart.” (Id. at 2:39-42; 2:52-54.)
`
`ANSWER:
`
`ContextMedia denies the allegation that the ’470 Patent discloses “innovations” or
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`discloses or claims patentable inventions. ContextMedia admits that the ‘470 Patent purports to
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`disclose an invention that “relates to a method and apparatus for controlling and coordinating
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`projectors in a digital information system for displaying information on at least one display
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`device through the medium of at least one projector for each said device, said information being
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`displayed in places that are accessible to and frequented by a general public.” ‘470 Patent col. 1
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`ll. 15-21. ContextMedia further admits that the ‘470 Patent states: “An object of the present
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`invention is to provide a flexible system in which external information mediators are able to
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`dynamically control in real time the transmission of display instructions to a larger public in
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`different places situated at any chosen distance apart through projectors which project
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`information onto displays intended therefor. Another object of the invention is to enable
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`pictures, images, messages and announcements to be configured in accordance with modern
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`digital technology, therewith providing rapid communication. A further object of the invention
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`is to enable a picture, image or other information to be changed in practice as often as is desired,
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`in real time, therewith providing direct and immediate communication, and to enable similar or
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`5
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`specific information to be displayed in places that are mutually far apart and to enable message
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`information to be alternated with advertising spots, for instance.” ‘470 Patent col. 2 ll. 39-56.
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`Except as expressly admitted, ContextMedia denies all other allegations set forth in paragraph 12
`
`of the Amended Complaint.
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`A system operating according to an embodiment of the ’470 Patent can include a
`13.
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`control center with a communication interface that connects devices to create and update a
`display list in real time using control instruction fields sent from external mediators and to
`transmit and display the desired images to one or more electronic displays that can be controlled
`independently of other electronic displays. (Id. at 3:4-19; 4:42-45.) In embodiments, the control
`center can include one or more servers, workstations, and databases stored on one or more
`physical storage devices, and can include redundancy, of both computer hardware and the
`information stored, where the devices can be connected using a network, such as a LAN (Local
`Area Network) or by using a cable-carried ISDN solution (Integrated Services Digital Network)
`or other fixed lines that have a similar capacity. (Id. at 4:57-5:16; 5:59-67; 6:41-59; 12:55-13:7.)
`In one embodiment of the devices or projectors, the projector is a large picture screen in LCD or
`LED technology or the like that includes or is connected to a computer. (Id. at 6:26-32.)
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`ANSWER:
`
`ContextMedia admits that the ‘470 Patent describes a control center that is “able to create
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`and update a display list in real time with control instruction fields via booking information for
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`display dynamically in time from mediators having drive routine means which are connected to
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`the subscription and which are transparent for the transmission of information to the drive
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`routine means of the control centre for transmission of information in the system. The display
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`list, which includes control instructions, coordinates and controls the projectors concerned with
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`regard to what shall be displayed, when it shall be displayed, where it shall be displayed and for
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`how long it shall be displayed, and causes each projector, independently of other projectors, to
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`receive the same or different information for display through respective projectors and through
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`the computerized devices, in accordance with the display list.” See ‘470 Patent col. 3 ll. 4-19.
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`ContextMedia further admits that the ‘470 Patent states that “[i]n the main, the system is
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`comprised of a control centre 12 having a communication interface 14 which connects an
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`6
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`unlimited number of computerized devices 16, 18, 20 which are placed at desired distances from
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`one another for the control of projectors 22 whose projector images or pictures are displayed in
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`the aforesaid public places.” See ‘470 Patent col. 4 ll. 42-47.
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`ContextMedia further admits that the ‘470 Patent states that “[t]he central computer 28 in
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`the control centre 12 also includes databases 30, in the illustrated case two databases. The
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`databases 30 may be externally connected to the central computer. The control centre also
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`includes working stations 32, which are preferably connected to the central computer 28 via a
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`Local Area Network (LAN) in accordance with known techniques.” See ‘470 Patent col. 4 ll. 57-
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`63. ContextMedia further admits that the ‘470 Patent states that “[t]he drawing shows
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`specifically a radio link which forms an interface between the control centre 12 and the
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`computerized devices 16, 18, 20, this interface being a preferred interface, although not
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`necessarily the sole possible interface. Other interfaces for transmitting information between the
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`control centre 12 and the computerized devices 16, 18, 20 may consist of a cable-carried ISDN
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`solution (Integrated Services Digital Network) or other fixed lines that have the same capacity.”
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`See ‘470 Patent col. 5 ll. 59-67. ContextMedia further admits that the ‘470 Patent states that
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`“[a]ccording to one embodiment, the computerized devices 16, 18, 20 may include redundancy
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`by virtue of all databases 36 of hard disks on the stations 16, 18, 20 including the same projector
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`control information or instructions for monitoring the system in a subway station 16, 18, 20.
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`Thus, all information is copied between the station computers 34 and their databases 36 via the
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`communications interface 14 from the central computer 28.” See ‘470 Patent col. 6 ll. 41-48.
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`ContextMedia further admits that the ‘470 Patent states that “when the server is sufficiently
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`powerful, only from one to two servers is required in the control centre 12, instead of three
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`servers 1, 2, 3 as is now the case.” See ‘470 Patent col. 12 ll. 65-67.
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`7
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`ContextMedia further admits that the ‘470 Patent describes an embodiment of “the
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`devices included in the computerized devices 16, 18, 20” where “the projector 22 is replaced
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`with an electronic display (not shown), such as a large picture screen in LCD technology, light-
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`emitting diode technology (LED technology) or the like. The station computer 34 is then
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`included in the large picture screen or is connected externally thereto.” See ‘470 Patent col. 6 ll.
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`26-32. ContextMedia is without sufficient information or knowledge to form a belief as to the
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`truth of the remaining allegations set forth in paragraph 13 of the Amended Complaint, and,
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`accordingly, denies the allegations.
`
`In one embodiment of the invention, personnel operating a work station can enter
`14.
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`information to be displayed from an external mediator via projector control instructions in the
`exposure list created by the server. (Id. at 8:10-26.) Operators are able to interrupt a queue in the
`server in order to update the exposure list with information generated centrally from the control
`center or with information from an external information mediator. (Id.)
`
`ANSWER:
`
`ContextMedia admits that the ‘470 Patent states that “[i]n one embodiment of the
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`invention, there is thus included an alternative to the dynamic updating of the exposure list as
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`mentioned in the aforegoing, i.e. the external information mediators 24 which do not have access
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`to software in the exposure handler are provided with the possibility of having their picture
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`material or exposure material processed by personnel serving the working stations 32, wherein
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`said personnel enter, via the working stations 32, the information that the external mediator 24
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`wishes to have exposed, or displayed, via projector control instructions in the exposure handler
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`and via the exposure list created by the handler. Personnel at the working stations 32 are thus
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`able to interrupt any queue lists in the server 1 to update the exposure list, via the exposure
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`handler, with information generated centrally from the control centre 12 or with information that
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`is insufficiently processed when received by the server 1 from the external information mediator
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`8
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`24.” See ‘470 Patent col. 8 ll. 10-26. ContextMedia is without sufficient information or
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`knowledge to form a belief as to the truth of the remaining allegations set forth in paragraph 14
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`of the Amended Complaint, and, accordingly, denies the allegations.
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`Information mediators can use an exposure program to deliver complete images
`15.
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`(e.g. an image, a series of images or a video clip) for display which would not require processing
`by the control center. (Id. at 11:19-28.) These can be dynamically added to the exposure list by
`the exposure handler. (Id.) External information mediators can thus deliver a complete image for
`display (an image, a series of images or a video clip) which can be processed automatically and
`inserted into the exposure list, or an administrator can select information from an external
`mediator and process the information so that it can be inserted into the exposure list via the
`exposure handler. (Id. at 8:27-41.)
`
`ANSWER:
`
`ContextMedia admits that the ‘470 Patent states that “[a] number of working machines or
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`working stations 32 are connected to the central computer 28 for controlling, communicating and
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`processing of exposure or picture material, generating exposure lists through the exposure
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`handler when required, and so on. Alternatively, the information mediators 24 may have their
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`own versions of the exposure program used, thereby enabling the mediators to deliver finished
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`picture sequences/films transparently. These picture sequences/films need not then be prepared
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`in the control centre 12, but can be filled dynamically in the exposure list by the exposure
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`handler.” See ‘470 Patent col. 11 ll. 19-28. ContextMedia further admits that the ‘470 Patent
`
`states that “[i]n accordance with the aforegoing, external information mediators 24 that have
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`access to the exposure program are able to deliver complete picture series/films which can be
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`processed automatically and inserted into the exposure list, or optionally personnel administering
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`the working stations 32 are able to pick external mediator information from the queues, or lines,
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`and process this information so that it can be inserted into the exposure list via the exposure
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`handler 3.” See ‘470 Patent col. 8 ll. 27-34. ContextMedia is without sufficient information or
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`9
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`Case: 1:16-cv-04826 Document #: 27 Filed: 08/29/16 Page 10 of 60 PageID #:1175
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`knowledge to form a belief as to the truth of the remaining allegations set forth in paragraph 15
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`of the Amended Complaint, and, accordingly, denies the allegations.
`
`The ‘334 Patent
`
`On June 3, 2008, U.S. Patent Number 7,382,334, entitled “Digital Information
`16.
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`System,” was duly and legally issued by the United States Patent and Trademark Office. A true
`and correct copy of the ’334 Patent is attached as Exhibit B to this Amended Complaint.
`
`ANSWER:
`
`ContextMedia admits that the face of U.S. Patent Number 7,382,334 indicates that it is
`
`entitled “Digital Information System,” and that it was issued by the United States Patent and
`
`Trademark Office on June 3, 2008. ContextMedia admits that Exhibit B attached to the
`
`Amended Complaint purports to be a copy of the ‘334 Patent. ContextMedia denies the
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`allegations in paragraph 16 insofar as they allege that the ‘334 Patent was duly and legally
`
`issued. ContextMedia is without sufficient information or knowledge to form a belief as to the
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`truth of the remaining allegations set forth in paragraph 16 of the Amended Complaint, and,
`
`accordingly, denies the allegations.
`
`The innovations described by the ’334 Patent relate to methods and arrangements
`17.
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`“for controlling and coordinating” digital display devices “in a digital information system for
`displaying information on at least one display device” “wherein the information is displayed in
`places that are accessible to and frequented by a general public.” (’334 Patent at Abstract; 1:13-
`24; 5:20-32.) The present invention is able “to provide a flexible system in which external
`information mediators are able to dynamically control in real time the transmission of display
`instructions to a larger public in different places” “and to enable similar or specific information
`to be displayed in places that are mutually far apart.” (Id. at 2:56-60; 3:5-11.)
`
`ANSWER:
`
`ContextMedia denies the allegation that the ’334 Patent discloses “innovations” or
`
`discloses or claims patentable inventions. ContextMedia admits that the ‘334 Patent purports to
`
`disclose an invention that relates to “a method and to an arrangement for controlling and
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`coordinating television sets, with peripheral equipment, or cameras, with peripheral equipment,
`
`
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`10
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`Case: 1:16-cv-04826 Document #: 27 Filed: 08/29/16 Page 11 of 60 PageID #:1176
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`in a digital information system for displaying information on at least one display device through
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`the medium of at least one television set or camera for each said device, said information being
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`displayed in places such as cinemas, private homes, onboard air-crafts, onboard trains, onboard
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`ships, main railway stations, subway stations, airport waiting lounges etc, and generally every
`
`were [sic] advertisements, films, movies and other information is displayed through the medium
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`of television sets or cameras.” ‘334 Patent col. 1 ll. 13-24. ContextMedia further admits that the
`
`‘334 Patent states, “[t]he present invention relates to a method for the dynamic coordination and
`
`control of television sets or cameras, with possible peripheral equipment, in a digital information
`
`system for displaying information on at least one display device via at least one television set or
`
`camera for each display device, wherein the information is displayed in places that are accessible
`
`to and frequented by the general public.” ‘334 Patent col. 5 ll. 20-25. ContextMedia admits that
`
`the ‘334 Patent purports to disclose an invention that “aims to provide a flexible system in which
`
`external information mediators are able to dynamically control in real time the transmission of
`
`display instructions to a larger public in different places situated at any chosen distance apart
`
`through television sets or cameras which project information onto displays intended herefor” and
`
`“enable[s] a picture, image or other information to be changed in practice as often as is desired,
`
`in real time, therewith providing direct and immediate communication, and to enable similar or
`
`specific information to be displayed in places that are mutually far apart and to enable message
`
`information to be alternated with advertising spots, for instance.” ‘334 Patent col. 2 ll. 56-61; col.
`
`3 ll. 5-11. Except as expressly admitted, ContextMedia denies all other allegations set forth in
`
`paragraph 17 of the Amended Complaint.
`
`A system operating according to an embodiment of the ’334 Patent can include a
`18.
`
`control center with a communication interface that connects devices to create and update a
`display list in real time using control instruction fields sent from external mediators and to
`transmit and display the desired images to one or more electronic displays that can be controlled
`
`
`
`11
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`independently of other electronic displays. (Id. at 3:38-60; 5:29-30.) In embodiments, the control
`center can include one or more servers, workstations, and databases stored on one or more
`physical storage devices, and can include redundancy, of both computer hardware and the
`information stored, where the devices can be connected using a network, such as a LAN (Local
`Area Network) or by using a cable-carried ISDN solution (Integrated Services Digital Network)
`or other fixed lines that have a similar capacity. (Id. at 6:17-45; 7:17-29; 11:60-67.) In some
`embodiments, a relational database can be used to store image and video data and each electronic
`display can be assigned a unique TCP/IP (Transmission Control Protocol / Internet Protocol)
`address such that each display can be individually addressed and sent content for display. (Id. at
`14:50-15:8.)
`
`ANSWER:
`
`ContextMedia admits that the ‘334 Patent states that “[i]nformation mediators are, in one
`
`embodiment of the present invention, connected to a computerized control center via interfaces
`
`for data and telecommunication for round-the clock transmission of information. The control
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`center has communication interfaces against computerized devices, situated at specific places
`
`remote from the control center, for coordinating and controlling television sets or cameras. A
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`control center is able to create and update an exposure list in real time with control instruction
`
`fields via dynamic booking of information in time for exposure from mediators having drive
`
`routine means. Said drive routine means may be transparent for transmission of information
`
`with the drive routine means of the control center for transmission of information in the system
`
`via interfaces. The exposure list with control instructions coordinates and controls the television
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`set or camera with regard to what shall be exposed, when it shall be exposed, where it shall be
`
`exposed and for how long it shall be exposed. Also it enables each television set or camera to be
`
`controlled, independently of other television sets or cameras, to receive the same or different
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`information in accordance with the exposure list for exposure of respective television set or
`
`camera through the computerized devices.” ‘334 Patent col. 3 ll. 38-60. ContextMedia further
`
`admits that the ‘334 Patent states that “the television set or camera itself can comprise a digital
`
`
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`12
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`display device or be incorporated in a digital display device such as an LCD display, PDP
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`display (Plasma Display Panel), a digital television set etc.” ‘334 Patent col. 5 ll. 29-32.
`
`ContextMedia further admits that the ‘334 Patent states that in certain embodiments
`
`“[t]he central computer 28 in the control center 12 also includes databases 30, in the illustrated
`
`case two databases. The databases 30 may be externally connected to the central computer. The
`
`control center also includes working stations 32, which are preferably connected to the central
`
`computer 28 via a Local Area Network (LAN) in accordance with known techniques.” ‘334
`
`Patent col. 6 ll. 17-23. ContextMedia further admits that the ‘334 Patent states that “the control
`
`center 12 has a communication interface 14 against the computerized devices 16, 18, 20 situated
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`on shifting positions or places for television set or camera coordination and control. The
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`drawing shows specifically a radio link which forms an interface between the control center 12
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`and the computerized devices 16, 18, 20, this interface being a preferred interface, although not
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`necessarily the sole possible interface. Other interfaces for transmitting information between the
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`control center 12 and the computerized devices 16, 18, 20 may consist of a cable-carried ISDN
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`solution (Integrated Services Digital Network), satellite network, other wireless network, or other
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`fixed lines that have the same capacity.” ‘334 Patent col. 7 ll. 17-29. ContextMedia further
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`admits that the ‘334 Patent states that “[e]ach server 1, 2, 3 will preferably have its own array of
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`databases 30, for instance external hard disks with sufficient storage capacity. All material is
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`copied therebetween. This will result in redundancy, since each exposure or picture will occur in
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`at least three copies. Copying between the databases 30, 36 can be effected automatically, with
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`each newly arrived or changed file containing information being copied in the remaining
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`databases.” ‘334 Patent col. 11 ll. 60-67.
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`13
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`Case: 1:16-cv-04826 Document #: 27 Filed: 08/29/16 Page 14 of 60 PageID #:1179
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`ContextMedia further admits that the ‘334 Patent states that “[i]n yet another embodiment
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`of the present invention, the central computer 28 comprises a relation database and/or, for
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`example, a video server of the type Oracle® which is able to optimally manage pictures and
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`films. The central computer 28 is connected 14 to network computers 34, 38 which control each
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`one television set or camera 22. Every television set or camera 22 or network computer 34, 38
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`has a TCP/IP address Transmission Control Protocol/Internet Protocol) [sic] and are able to be
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`addressed by the central computer 28 and vice versa. TCP/IP is a transmission and Internet
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`protocol which de facto is a network standard. It is commonly used in connection with X25 and
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`Ethernet® connections and is regarded as one of few protocols which provide a true connection
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`to OSI (Open Systems Interconnection). The TCP/IP address allows addressing of unique output
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`data such as pictures to every television set or camera 22, respectively. With the existing
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`Oracle® relation database the comprised accounting or statistic software for invoicing of
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`purchased advertising time can be used. A relation database is a type of database system where
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`all the data is stored together with indications of specific connections (relations) between stored
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`information which simplifies searching, printing, sorting etc. in the database 30 or outputs from
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`it.” ‘334 Patent col. 14 ll. 50-67, col. 15 ll. 1-8. ContextMedia is without sufficient information
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`or knowledge to form a belief as to the truth of the remaining allegations set forth in paragraph
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`18 of the Amended Complaint, and, accordingly, denies the allegations.
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`In one embodiment of the invention, personnel operating a work station can enter
`19.
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`information to be displayed from an external mediator via projector control instructions in the
`exposure list created by the server. (Id. at 9:45-61.) Operators are able to interrupt a queue in the
`server in order to update the exposure list with information generated centrally from the control
`center or with information from an external information mediator. (Id.)
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`ANSWER:
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`14
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`Case: 1:16-cv-04826 Document #: 27 Filed: 08/29/16 Page 15 of 60 PageID #:1180
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`ContextMedia admits that the ‘334 Patent states that “[i]n one embodiment of the
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`invention, there is thus included an alternative to the dynamic updating of the exposure list as
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`mentioned in the aforegoing, i.e. the external information mediators 24 which do not have access
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`to software in the exposure handler are provided with the possibility of having their picture
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`material or exposure material processed by personnel serving the working