Case 1:20-cv-00034-ADA Document 18 Filed 10/25/19 Page 1 of 15
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`ANCORA TECHNOLOGIES, INC.
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`Plaintiff,
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`v.
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`LG ELECTRONICS INC., and LG
`ELECTRONICS U.S.A., INC.,
`
`Defendants.
`
`§
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`§
`§
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`Civil Action No. 6:19-cv-384
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`Jury Trial Requested
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`DEFENDANTS LG ELECTRONICS INC. AND LG ELECTRONICS U.S.A., INC.’S
`ANSWER AND COUNTERCLAIMS TO PLAINTIFF’S ORIGINAL COMPLAINT
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`Defendants LG Electronics Inc. (“LGEKR”) and LG Electronics U.S.A., Inc. (“LGEUS”)
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`(collectively, “LGE”) hereby submit their Answer (“Answer”) and Counterclaims to Plaintiff
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`Ancora Technologies, Inc.’s Original Complaint (“Complaint”). Except as otherwise admitted in
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`this Answer, LGE denies each and every allegation in the Complaint.
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`RELATED CASE
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`1.
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`LGE admits that Plaintiff filed an action styled as Ancora Technologies, Inc. v.
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`Samsung Electronics, Co., Ltd., et al., and that it was filed on June 21, 2019 in the United States
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`District Court for the Western District of Texas, Waco Division. LGE is without sufficient
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`knowledge or information to form a relief as to the truth of the remaining allegations set forth in
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`this paragraph of the Complaint and therefore denies the same.
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`PARTIES
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`2.
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`LGE is without sufficient knowledge or information to form a belief as to the
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`truth of the allegations set forth in this paragraph of the Complaint and therefore denies the same.
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`3.
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`LGEKR admits that LGEKR is a company incorporated under the laws of the
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`
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`ANCORA TECHNOLOGIES, INC.
`
`Plaintiff,
`
`v.
`
`LG ELECTRONICS INC., and LG
`ELECTRONICS U.S.A., INC.,
`
`Defendants.
`
`§
`§
`§
`§
`§
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`§
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`§
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`
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`Civil Action No. 6:19-cv-384
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`Jury Trial Requested
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`DEFENDANTS LG ELECTRONICS INC. AND LG ELECTRONICS U.S.A., INC.’S
`ANSWER AND COUNTERCLAIMS TO PLAINTIFF’S ORIGINAL COMPLAINT
`
`Defendants LG Electronics Inc. (“LGEKR”) and LG Electronics U.S.A., Inc. (“LGEUS”)
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`(collectively, “LGE”) hereby submit their Answer (“Answer”) and Counterclaims to Plaintiff
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`Ancora Technologies, Inc.’s Original Complaint (“Complaint”). Except as otherwise admitted in
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`this Answer, LGE denies each and every allegation in the Complaint.
`
`RELATED CASE
`
`1.
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`LGE admits that Plaintiff filed an action styled as Ancora Technologies, Inc. v.
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`Samsung Electronics, Co., Ltd., et al., and that it was filed on June 21, 2019 in the United States
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`District Court for the Western District of Texas, Waco Division. LGE is without sufficient
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`knowledge or information to form a relief as to the truth of the remaining allegations set forth in
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`this paragraph of the Complaint and therefore denies the same.
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`PARTIES
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`2.
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`LGE is without sufficient knowledge or information to form a belief as to the
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`truth of the allegations set forth in this paragraph of the Complaint and therefore denies the same.
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`3.
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`LGEKR admits that LGEKR is a company incorporated under the laws of the
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`Case 1:20-cv-00034-ADA Document 18 Filed 10/25/19 Page 2 of 15
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`Republic of Korea with a place of business at LG Twin Towers, 128 Yeoui-daero,
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`Yeongdeungpo-gu, South Korea. LGE denies the remaining allegations in this paragraph of the
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`Complaint.
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`4.
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`LGEUS admits that LGEUS is a Delaware corporation. LGE denies the
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`remaining allegations in this paragraph of the Complaint.
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`5.
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`LGEUS admits that LGEUS assumed all of the rights and obligations of LG
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`Electronics MobileComm U.S.A., Inc. on August 1, 2018. LGEUS admits that Dkt. 144 filed in
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`3G Licensing S.A., et al. v. LG Electronics Inc., et al., Case No. 1:17-cv-00085-LPS (D. Del.)
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`speaks for itself and no response is necessary. LGE denies the remaining allegations in this
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`paragraph of the Complaint.
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`6.
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`LGEUS admits that LGEUS assumed all of the rights and obligations of LG
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`Electronics MobileComm U.S.A., Inc. on August 1, 2018. LGE denies the remaining allegations
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`in this paragraph of the Complaint.
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`JURISDICTION AND VENUE
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`7.
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`LGE admits that this action purportedly arises under the patent laws of the United
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`States, Title 35 of the United States Code. LGE denies that it has committed any acts of
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`infringement as alleged in the Complaint and denies any remaining allegations in this paragraph
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`of the Complaint.
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`8.
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`LGE admits that this Court has jurisdiction over the subject matter of actions
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`arising under §§ 1331 and 1338(a). LGE denies that it has committed any acts of infringement
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`as alleged in the Complaint and denies any remaining allegations in this paragraph of the
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`Complaint.
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`9.
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`This paragraph of the Complaint sets out a legal conclusion to which no response
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`Case 1:20-cv-00034-ADA Document 18 Filed 10/25/19 Page 3 of 15
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`is necessary. LGEKR and LGEUS do not contest that this Court has personal jurisdiction over
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`them for the purposes of this action only, but do not waive the right to contest personal
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`jurisdiction in any other case or action in this District. LGE denies that it has committed any acts
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`of infringement in this District or elsewhere. LGE denies the remaining allegations in this
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`paragraph of the Complaint.
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`10.
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`11.
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`12.
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`13.
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`14.
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`Denied.
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`Denied.
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`Denied.
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`Denied.
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`This paragraph of the Complaint sets out a legal conclusion to which no response
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`is necessary. To the extent a response is required, LGEKR and LGEUS do not contest the
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`propriety of venue at this time and for this action only, but do not waive the right to contest the
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`propriety of venue in another action or to seek transfer to a more convenient forum later in this or
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`another action.
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`15.
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`This paragraph of the Complaint sets out a legal conclusion to which no response
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`is necessary. LGEKR admits that LGEKR is a corporation incorporated under the laws of the
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`Republic of Korea. LGE denies the remaining allegations in this paragraph of the Complaint.
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`THE ASSERTED PATENT
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`16.
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`LGE admits that this lawsuit purportedly asserts causes of action for alleged
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`infringement of United States Patent No. 6,411,941 (“the ’941 patent”). LGE admits that Exhibit
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`A purports to be a true and correct copy of the ’941 patent, which on its face bears the title
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`“Method of Restricting Software Operation Within a License Limitation,” but LGE is without
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`knowledge or information sufficient to form a belief as to the accuracy of this assertion and
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`Case 1:20-cv-00034-ADA Document 18 Filed 10/25/19 Page 4 of 15
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`therefore denies the same. LGE denies that it has committed any acts of infringement as alleged
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`in the Complaint.
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`17.
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`LGE admits that the ’941 patent on its face indicates it issued on June 25, 2002.
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`LGE is without sufficient knowledge or information to form a belief as to the truth of the
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`remaining allegations set forth in this paragraph of the Complaint and therefore denies the same.
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`18.
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`LGE is without sufficient knowledge or information to form a belief as to the
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`truth of the allegations set forth in this paragraph of the Complaint and therefore denies the same.
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`19.
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`LGE admits that the ’941 patent on its face lists Miki Mullor as one of the
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`inventors. LGE is without sufficient knowledge or information to form a belief as to the truth of
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`the remaining allegations set forth in this paragraph of the Complaint and therefore denies the
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`same.
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`20.
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`LGE admits that Exhibit A purportedly includes a true and correct copy of a
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`reexamination certificate for the ’941 patent, which on its face indicates that it issued on June 1,
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`2010, but LGE is without knowledge or information sufficient to form a belief as to the accuracy
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`of this assertion and therefore denies the same.
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`21.
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`LGE is without sufficient knowledge or information to form a belief as to the
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`truth of the allegations set forth in this paragraph of the Complaint and therefore denies the same.
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`22.
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`This paragraph of the Complaint purportedly refers to decisions by a court or
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`courts in litigations involving the ’941 patent. The decisions speak for themselves and no
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`response is necessary. To the extent that this paragraph of the Complaint interprets the court
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`decisions, it sets out a legal conclusion to which no response is necessary. LGE is without
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`sufficient knowledge or information to form a belief as to the truth of any remaining allegations
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`set forth in this paragraph of the Complaint and therefore denies the same.
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`Case 1:20-cv-00034-ADA Document 18 Filed 10/25/19 Page 5 of 15
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`23.
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`Ancora Techs., Inc. v. Apple Inc., No. 11-CV-06357 YGR, 2012 WL 6738761
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`(N.D. Cal. Dec. 31, 2012) speaks for itself and no response is necessary. To the extent that this
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`paragraph of the Complaint interprets the cited court decision, it sets out a legal conclusion to
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`which no response is necessary. LGE is without sufficient knowledge or information to form a
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`belief as to the truth of any remaining allegations set forth in this paragraph of the Complaint and
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`therefore denies the same.
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`24.
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`Ancora Techs., Inc. v. Apple Inc., No. 11-CV-06357 YGR, 2012 WL 6738761
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`(N.D. Cal. Dec. 31, 2012) speaks for itself and no response is necessary. To the extent that this
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`paragraph of the Complaint interprets the cited court decision, it sets out a legal conclusion to
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`which no response is necessary. LGE is without sufficient knowledge or information to form a
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`belief as to the truth of any remaining allegations set forth in this paragraph of the Complaint and
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`therefore denies the same.
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`25.
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`The decision of the United States Court of Appeals for the Federal Circuit (“the
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`Federal Circuit”) in Ancora Techs., Inc. v. Apple Inc., 744 F.3d 732 (Fed. Cir. 2014) speaks for
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`itself and no response is necessary. To the extent that this paragraph of the Complaint interprets
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`the cited decision by the Federal Circuit, it sets out a legal conclusion to which no response is
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`necessary. LGE is without sufficient knowledge or information to form a belief as to the truth of
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`any remaining allegations set forth in this paragraph of the Complaint and therefore denies the
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`same.
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`26.
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`The decision of the Federal Circuit in Ancora Techs., Inc. v. Apple Inc., 744 F.3d
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`732 (Fed. Cir. 2014) speaks for itself and no response is necessary. To the extent that this
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`paragraph of the Complaint interprets the cited decision by the Federal Circuit, it sets out a legal
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`conclusion to which no response is necessary. LGE is without sufficient knowledge or
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`Case 1:20-cv-00034-ADA Document 18 Filed 10/25/19 Page 6 of 15
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`information to form a belief as to the truth of any remaining allegations set forth in this
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`paragraph of the Complaint and therefore denies the same.
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`27.
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`The decision of the Federal Circuit in Ancora Techs., Inc. v. HTC Am., Inc., 708
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`F.3d 1343 (Fed. Cir. 2018), as amended (Nov. 20, 2018) speaks for itself and no response is
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`necessary. To the extent that this paragraph of the Complaint interprets the cited decision by the
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`Federal Circuit, it sets out a legal conclusion to which no response is necessary. LGE is without
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`sufficient knowledge or information to form a belief as to the truth of any remaining allegations
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`set forth in this paragraph of the Complaint and therefore denies the same.
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`28.
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`LGE admits that what purports to be a true and correct copy of a decision by the
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`Patent Trial and Appeal Board (“the Board”) regarding the ’941 patent is attached as Exhibit B to
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`the Complaint. The decision by the Board speaks for itself and no response is necessary. To the
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`extent that this paragraph of the Complaint interprets this decision by the Board, it sets out a
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`legal conclusion to which no response is necessary. LGE is without sufficient knowledge or
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`information to form a belief as to the truth of any remaining allegations set forth in this
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`paragraph of the Complaint and therefore denies the same.
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`COUNT 1 – [PURPORTED] INFRINGEMENT
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`29.
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`LGE repeats and incorporates by reference each of the answers in paragraphs 1
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`through 28 above as if fully set forth herein.
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`30.
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`31.
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`32.
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`33.
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`34.
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`Denied.
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`Denied.
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`Denied.
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`Denied.
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`LGE admits that claim 1 of the ’941 patent on its face recites: “A method of
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`Case 1:20-cv-00034-ADA Document 18 Filed 10/25/19 Page 7 of 15
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`restricting software operation within a license for use with a computer including an erasable,
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`non-volatile memory area of a BIOS of the computer, and a volatile memory area; the method
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`comprising the steps of:
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`selecting a program residing in the volatile memory,
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`using an agent to set up a verification structure in the erasable, non-volatile memory of
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`the BIOS, the verification structure accommodating data that includes at least one
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`license record,
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`verifying the program using at least the verification structure from the erasable non-
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`volatile memory of the BIOS, and
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`acting on the program according to the verification.”
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`LGE denies any remaining allegations in this paragraph of the Complaint.
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`35.
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`36.
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`Denied.
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`LGE admits that the LG G5 contains ROM and RAM. LGE is without sufficient
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`knowledge or information to form a belief as to the truth of the remaining allegations set forth in
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`this paragraph of the Complaint and therefore denies the same.
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`37.
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`38.
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`Denied.
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`LGE is without sufficient knowledge or information to form a belief as to the
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`truth of the allegations set forth in this paragraph of the Complaint and therefore denies the same.
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`39.
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`LGE is without sufficient knowledge or information to form a belief as to the
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`truth of the allegations set forth in this paragraph of the Complaint and therefore denies the same.
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`40.
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`LGE is without sufficient knowledge or information to form a belief as to the
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`truth of the allegations set forth in this paragraph of the Complaint and therefore denies the same.
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`41.
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`LGE is without sufficient knowledge or information to form a belief as to the
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`Case 1:20-cv-00034-ADA Document 18 Filed 10/25/19 Page 8 of 15
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`truth of the allegations set forth in this paragraph of the Complaint and therefore denies the same.
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`42.
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`LGE is without sufficient knowledge or information to form a belief as to the
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`truth of the allegations set forth in this paragraph of the Complaint and therefore denies the same.
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`43.
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`44.
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`45.
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`46.
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`47.
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`48.
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`Denied.
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`Denied.
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`Denied.
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`Denied.
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`Denied.
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`LGE admits that any “Manufacturer’s Warranty” at www.lg.com/us/mobile-
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`phones/arbitration/legalterms speaks for itself and no response is necessary. LGE denies any
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`remaining allegations set forth in this paragraph of the Complaint.
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`49.
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`50.
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`Denied.
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`LGE admits that this paragraph of the Complaint purports to cite information
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`from https://www.lg.com/uk/support/solutions/audio-video/software-update, which is a webpage
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`containing information relating to LG products in the U.K. The webpage speaks for itself and no
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`response is necessary. LGE denies any remaining allegations set forth in this paragraph of the
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`Complaint.
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`51.
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`LGE admits that this paragraph of the Complaint purports to cite information
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`from https://www.lg.com/uk/support/solutions/mobile/android-7-nougat, which is a webpage
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`containing information relating to LG products in the U.K. The webpage speaks for itself and no
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`response is necessary. LGE denies any remaining allegations set forth in this paragraph of the
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`Complaint.
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`52.
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`LGE is without sufficient knowledge or information to form a belief as to the
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`Case 1:20-cv-00034-ADA Document 18 Filed 10/25/19 Page 9 of 15
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`truth of the allegations set forth in this paragraph of the Complaint and therefore denies the same.
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`53.
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`54.
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`55.
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`56.
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`Denied.
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`Denied.
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`Denied.
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`Denied.
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`DEMAND FOR JURY TRIAL
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`57.
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`LGE admits that Plaintiff has demanded a trial by jury.
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`PRAYER FOR RELIEF
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`LGE denies that Plaintiff is entitled to any relief from LGE, whether sought in the Prayer
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`for Relief or otherwise. Plaintiff’s Prayer for Relief should, therefore, be denied in its entirety
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`and with prejudice, and Plaintiff should take nothing from LGE.
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`DEFENSES AND AFFIRMATIVE DEFENSES
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`LGE asserts the following defenses and affirmative defenses without assuming any
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`burden of proof that rightfully should be placed on Plaintiff. Furthermore, LGE repeats and
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`incorporates by reference each of its answers in paragraphs 1 through 57, the Demand for Jury
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`Trial, and Prayer for Relief as set forth above with each of the following defenses as if fully set
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`forth herein.
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`FIRST DEFENSE
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`LGE has not infringed and does not infringe any valid and enforceable claim of the ’941
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`patent, either directly or indirectly, either literally or under the doctrine of equivalents, because
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`the accused instrumentalities do not practice every claimed limitation.
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`Case 1:20-cv-00034-ADA Document 18 Filed 10/25/19 Page 10 of 15
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`SECOND DEFENSE
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`The claims of the ’941 patent are invalid for failure to meet the requirements of one or
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`more sections of Title 35, United States Code, and/or Title 37, Code of Federal Regulations,
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`including but not limited to one or more of 35 U.S.C. §§ 101, 102, 103, and 112.
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`THIRD DEFENSE
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`Plaintiff’s claims against LGE are barred, in whole or in part, by the doctrines of
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`prosecution history estoppel and disclaimer, in particular based on statements or arguments made
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`during prosecution of the relevant patent applications.
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`FOURTH DEFENSE
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`Plaintiff’s claims against LGE for recovery are barred, in whole or in part, by 35 U.S.C.
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`§ 286. For the purposes of this defense, the relevant calculation period for damages—as
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`prescribed by statute—cannot be more than six years prior to the filing of the Complaint for
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`alleged infringement in this action before the Court in the Western District of Texas.
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`FIFTH DEFENSE
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`Plaintiff’s claims against LGE for recovery are barred, in whole or in part, by 35 U.S.C.
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`§ 287, in particular for failure to comply with the marking statute, and Plaintiff has not plead
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`compliance with the marking statute.
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`SIXTH DEFENSE
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`Plaintiff’s claims against LGE for recovery are barred, in whole or in part, by 35 U.S.C.
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`§ 288.
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`SEVENTH DEFENSE
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`Plaintiff’s claims against LGE for recovery are barred, in whole or in part, by license,
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`release, waiver, or exhaustion.
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`Case 1:20-cv-00034-ADA Document 18 Filed 10/25/19 Page 11 of 15
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`EIGHTH DEFENSE
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`LGE has not committed any acts of infringement, willful or otherwise, in this District or
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`elsewhere, and the ’941 patent is invalid, and thus Plaintiff cannot prove that it is entitled to
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`enhanced damages or that this case is otherwise exceptional under 35 U.S.C. § 285.
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`NINTH DEFENSE
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`Plaintiff’s Complaint fails to state facts sufficient to support a claim of action and fails to
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`state any claim against LGE for which relief may be granted. For example, Plaintiff fails to plead
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`facts sufficient to show violation of 35 U.S.C. § 271(a) by LGE prior to the expiration of the ’941
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`patent, fails to plead facts sufficient to show that Plaintiff is entitled to recover any damages for
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`the alleged infringement prior to the filing of the Complaint, and fails to plead facts sufficient to
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`show that LGE has acted in an exceptional manner to warrant enhanced damages or any relief
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`under 35 U.S.C. § 285 to Plaintiff.
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`RIGHT TO AMEND ANSWER
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`LGE reserves the right to amend its Answer to assert further defenses based on future
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`discovery in this lawsuit.
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`COUNTERCLAIMS FOR DECLARATORY JUDGMENT
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`Counterclaim-Plaintiff LG Electronics Inc. (“LGEKR”) and LG Electronics U.S.A., Inc.
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`(“LGEUS”) (collectively, “LGE”), on personal knowledge as to their own acts, and on
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`information and belief as to all others, alleges Counterclaims against Counterclaim-Defendant
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`Ancora Technologies. (“Ancora”) as follows:
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`THE PARTIES
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`1.
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`Counterclaim-Plaintiff LG Electronics Inc. is a South Korean corporation, with a
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`place of business at LG Twin Towers, 128 Yeoui-daero, Yeongdeungpo-gu, South Korea.
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`2.
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`Counterclaim-Plaintiff LG Electronics U.S.A., Inc. is a Delaware corporation,
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`with a place of business in Englewood Cliffs, New Jersey.
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`3.
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`According to the allegations in paragraph 2 of the Complaint, Counterclaim-
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`Defendant Ancora Technologies, Inc. is a corporation organized and existing under the laws of
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`the State of Delaware with a place of business at 23977 S.E. 10th Street, Sammamish,
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`Washington 98075.
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`JURISDICTION AND VENUE
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`4.
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`These Counterclaims arise under the patent laws of the United States, 35 U.S.C.
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`§ 1 et seq., and the Declaratory Judgment Act, 28 U.S.C. §§ 2201–02.
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`5.
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`This Court has subject matter jurisdiction over these Counterclaims under 28
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`U.S.C. §§ 1331, 1338, and 2201–02.
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`6.
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`This Court has personal jurisdiction over Counterclaim-Defendant Ancora
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`because it consented to jurisdiction of this Court by filing this action against LGE in this Court.
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`7.
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`Venue
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`for
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`these Counterclaims
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`is proper
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`in
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`this District because
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`Counterclaim-Defendant Ancora consented to the propriety of venue in this District by filing this
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`action against LGE in this Court.
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`COUNTERCLAIM COUNT I
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`Declaratory Judgment of Non-Infringement of U.S. Patent No. 6,411,941
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`8.
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`LGE incorporates and re-alleges paragraphs 1–57 of its Answer, each of its
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`Defenses and Affirmative Defenses, and paragraph 1–7 of its Counterclaims.
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`9.
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`As reflected in the Complaint and LGE’s Answer thereto, an actual controversy
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`exists with respect to the alleged infringement of U.S. Patent No. 6,411,941 (the “’941 patent”).
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`Case 1:20-cv-00034-ADA Document 18 Filed 10/25/19 Page 13 of 15
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`10.
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`Although Counter-Defendant Ancora alleges in its Complaint that LGE infringed
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`the claims of the ’941 patent, LGE has denied these allegations and contends that LGE has not
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`infringed, and does not infringe, any valid and enforceable claim of the ’941 patent, directly,
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`indirectly, literally, or under the doctrine of equivalents. A justiciable controversy therefore
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`exists between Ancora and LGE.
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`11.
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`By this Counterclaim, LGE seeks a declaratory judgment pursuant to 28 U.S.C.
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`§ 2201(a) that it does not infringe the ’941 patent or any valid and enforceable claims thereof.
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`12.
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`A judicial determination of the respective rights of the parties with respect to the
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`non-infringement of the claims of the ’941 patent is now necessary and appropriate under 28
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`U.S.C. § 2201.
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`COUNTERCLAIM COUNT II
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`Declaratory Judgment of Invalidity of U.S. Patent No. 6,411,941
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`13.
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`LGE incorporates and re-alleges paragraphs 1–57 of its Answer, each of its
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`Defenses and Affirmative Defenses, and paragraphs 1–12 of its Counterclaims.
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`14.
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`As reflected in the Complaint and LGE’s Answer thereto, an actual controversy
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`exists with respect to the alleged validity of the ’941 patent.
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`15.
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`Although Counterclaim-Defendant Ancora alleges in its Complaint that the ’941
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`patent is valid and was duly issued, LGE has denied these allegations and contends that the ’941
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`patent is invalid because it fails to satisfy one or more conditions for patentability set forth in 35
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`U.S.C. § 101 et seq., including, but not limited to, sections 101, 102, 103, and 112. A justiciable
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`controversy therefore exists between Counterclaim-Defendant Ancora and LGE.
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`16.
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`By this Counterclaim, LGE seeks a declaratory judgment pursuant to 28 U.S.C.
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`§ 2201(a) that the ’941 patent is invalid under 35 U.S.C. §§ 101, 102, 103, and/or 112.
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`Case 1:20-cv-00034-ADA Document 18 Filed 10/25/19 Page 14 of 15
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`17.
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`A judicial determination of the respective rights of the parties with respect to the
`
`invalidity of the claims of the ’941 patent is now necessary and appropriate under 28 U.S.C.
`
`§ 2201.
`
`DEMAND FOR JURY TRIAL
`
`LGE demands a trial by jury of all issues so triable in this action.
`
`PRAYER FOR RELIEF
`
`LGE prays for the following relief:
`
`A.
`
`That Counterclaim-Defendant Ancora’s claims against LGE be dismissed with
`
`prejudice and that Counterclaim-Defendant Ancora takes nothing by way of its Complaint;
`
`B.
`
`C.
`
`That judgment be rendered in favor of LGE;
`
`For a declaration that LGE has not infringed any valid and enforceable claim of
`
`the ’941 patent, directly, indirectly, literally, or under the doctrine of equivalents;
`
`D.
`
`E.
`
`For a declaration that the claims of the ’941 patent are invalid;
`
`For an order finding this case exceptional under 35 U.S.C. § 285 in LGE’s favor
`
`and awarding LGE its reasonable attorneys’ fees and costs;
`
`F.
`
`G.
`
`That LGE be awarded its costs incurred in this action; and
`
`For such other and further relief as this Court deems just and proper.
`
`14
`
`
`
`Case 1:20-cv-00034-ADA Document 18 Filed 10/25/19 Page 15 of 15
`
`Date: October 25, 2019
`
`Respectfully submitted,
`
`
`
`/s/ Elizabeth M. Chiaviello
`Winstol D. Carter, Jr.
`Texas Bar No. 03932950
`winn.carter@morganlewis.com
`Thomas R. Davis
`Texas Bar No. 24055384
`thomas.davis@morganlewis.com
`Elizabeth M. Chiaviello
`Texas Bar No. 24088913
`elizabeth.chiaviello@morganlewis.com
`MORGAN, LEWIS & BOCKIUS LLP
`1000 Louisiana Street, Suite 4000
`Houston, Texas 77002-5006
`T. 713.890.5000
`F. 713.890.5001
`
`Collin W. Park (Pro hac vice to be filed)
`collin.park@morganlewis.com
`District of Columbia Bar No. 470486
`MORGAN, LEWIS & BOCKIUS LLP
`1111 Pennsylvania Avenue, NW
`Washington, D.C. 20004-2541
`T. 202.739.3000
`F. 202.739.3001
`
`Attorneys for Defendants LG Electronics Inc.
`and LG Electronics U.S.A., Inc.
`
`CERTIFICATE OF SERVICE
`
`The undersigned counsel hereby certifies that on October 25, 2019, a true and correct
`
`copy of the foregoing response was served on all counsel of record who have appeared in this
`
`case via the Court’s CM/ECF system per Local Rule CV-5.
`
`By:
`
`/s/ Elizabeth M. Chiaviello
`Elizabeth M. Chiaviello
`
`15
`
`
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