Case 1:11-cv-00797-RGA Document 103 Filed 01/06/12 Page 1 of 14 PageID #: 638
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`Civil Action No. 11-797-RGA
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`
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`JURY TRIAL DEMANDED
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`FASTVDO LLC,
`
`Plaintiff,
`
`
`
`
`
`
`
`v.
`
`APPLE, INC.; CANON U.S.A., INC.;
`CASIO AMERICA, INC.; CISCO
`SYSTEMS, INC.; DXG TECHNOLOGY
`(U.S.A.) INC; EASTMAN KODAK
`COMPANY; FUJIFILM NORTH
`AMERICA CORPORATION; HEWLETT
`PACKARD COMPANY; JVC
`AMERICAS CORPORATION; LITE-ON
`SALES AND DISTRIBUTION, INC.;
`NIKON AMERICAS, INC.; NIKON,
`INC.; OLYMPUS IMAGING AMERICA
`INC.; PANASONIC CORPORATION OF
`NORTH AMERICA; SAMSUNG
`ELECTRONICS AMERICA INC.;
`SANYO NORTH AMERICA
`CORPORATION; SONY
`CORPORATION OF AMERICA; SONY
`ELECTRONICS, INC.; and TOSHIBA
`AMERICA INFORMATION SYSTEMS,
`INC.,
`
`
`
`Defendants.
`
`
`
`
`
`DEFENDANT OLYMPUS IMAGING AMERICA INC.’S
`ANSWER TO PLAINTIFF FASTVDO LLC’S FIRST AMENDED COMPLAINT
`
`Defendant Olympus Imaging America Inc. (“Olympus” or “Defendant”) answers Plaintiff
`
`FastVDO LLC’s (“FastVDO” or “Plaintiff”) First Amended Complaint (the “Complaint”) as
`
`follows:
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`Civil Action No. 11-797-RGA
`
`
`
`JURY TRIAL DEMANDED
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`FASTVDO LLC,
`
`Plaintiff,
`
`
`
`
`
`
`
`v.
`
`APPLE, INC.; CANON U.S.A., INC.;
`CASIO AMERICA, INC.; CISCO
`SYSTEMS, INC.; DXG TECHNOLOGY
`(U.S.A.) INC; EASTMAN KODAK
`COMPANY; FUJIFILM NORTH
`AMERICA CORPORATION; HEWLETT
`PACKARD COMPANY; JVC
`AMERICAS CORPORATION; LITE-ON
`SALES AND DISTRIBUTION, INC.;
`NIKON AMERICAS, INC.; NIKON,
`INC.; OLYMPUS IMAGING AMERICA
`INC.; PANASONIC CORPORATION OF
`NORTH AMERICA; SAMSUNG
`ELECTRONICS AMERICA INC.;
`SANYO NORTH AMERICA
`CORPORATION; SONY
`CORPORATION OF AMERICA; SONY
`ELECTRONICS, INC.; and TOSHIBA
`AMERICA INFORMATION SYSTEMS,
`INC.,
`
`
`
`Defendants.
`
`
`
`
`
`DEFENDANT OLYMPUS IMAGING AMERICA INC.’S
`ANSWER TO PLAINTIFF FASTVDO LLC’S FIRST AMENDED COMPLAINT
`
`Defendant Olympus Imaging America Inc. (“Olympus” or “Defendant”) answers Plaintiff
`
`FastVDO LLC’s (“FastVDO” or “Plaintiff”) First Amended Complaint (the “Complaint”) as
`
`follows:
`
`
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`Case 1:11-cv-00797-RGA Document 103 Filed 01/06/12 Page 2 of 14 PageID #: 639
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`PARTIES
`
`1.
`
`Olympus admits that FastVDO alleges that it is a Florida limited liability
`
`corporation with a principal place of business at 750 N. Atlantic Ave., Cocoa Beach, FL 32931.
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`2.
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`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 2 and therefore denies them.
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`3.
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`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 3 and therefore denies them.
`
`4.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 4 and therefore denies them.
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`5.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 5 and therefore denies them.
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`6.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 6 and therefore denies them.
`
`7.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 7 and therefore denies them.
`
`8.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 8 and therefore denies them.
`
`9.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 9 and therefore denies them.
`
`10.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 10 and therefore denies them.
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`11.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 11 and therefore denies them.
`
`2
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`Case 1:11-cv-00797-RGA Document 103 Filed 01/06/12 Page 3 of 14 PageID #: 640
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`12.
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`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 12 and therefore denies them.
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`13.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 13 and therefore denies them.
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`14.
`
`Olympus admits that it is a New York corporation with a principal place of
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`business at 3500 Corporate Parkway, Center Valley, PA 18034.
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`15.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 15 and therefore denies them.
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`16.
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`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 16 and therefore denies them.
`
`17.
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`Olympus is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 17 and therefore denies them.
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`18.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 18 and therefore denies them.
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`19.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 19 and therefore denies them.
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`20.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 20 and therefore denies them.
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`JURISDICTION AND VENUE
`
`21.
`
`Olympus admits that FastVDO purports to bring an action and assert claims
`
`arising under the laws listed in Paragraph 21. Olympus admits that FastVDO has invoked
`
`28 U.S.C. §§ 1331 and 1338(a) as the basis for subject matter jurisdiction in this Court. To the
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`extent Paragraph 21 contains any remaining allegations requiring a response, they are denied.
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`3
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`Case 1:11-cv-00797-RGA Document 103 Filed 01/06/12 Page 4 of 14 PageID #: 641
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`22.
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`Olympus denies that it has committed any acts of patent infringement alleged in
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`FastVDO’s First Amended Complaint. Olympus is without knowledge or information sufficient
`
`to form a belief as to the truth of allegations in Paragraph 22 concerning other parties and
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`therefore denies them. To the extent Paragraph 22 contains any remaining allegations requiring
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`a response, they are denied.
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`23.
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`Olympus admits that FastVDO has invoked 28 U.S.C. §§ 1391(b)-(c) and 1400(b)
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`as the basis for venue in this district. Olympus denies that it has committed any acts of
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`infringement alleged in FastVDO’s First Amended Complaint. Olympus is without knowledge
`
`or information sufficient to form a belief as to the truth of allegations in Paragraph 23 concerning
`
`other parties and therefore denies them. To the extent that Paragraph 23 contains any remaining
`
`allegations requiring a response, they are denied.
`
`COUNT I
`(INFRINGEMENT OF U.S. PATENT NO. RE40,081)
`
`24.
`
`Upon information and belief, Olympus admits that FastVDO is listed as an
`
`assignee of U.S. Patent No. RE40,081 (“the ’081 patent”) in records of the United States Patent
`
`and Trademark Office. Upon information and belief, Olympus admits that the title of the ’081
`
`patent is “Fast Signal Transforms With Lifting Steps.” Upon information and belief, Olympus
`
`admits that the ’081 patent reissued on February 19, 2008, and admits that a purported copy of
`
`the ’081 patent is attached to the First Amended Complaint as Exhibit A, which document speaks
`
`for itself. To the extent that Paragraph 24 contains any remaining allegations requiring a
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`response, they are denied.
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`25.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 25 and therefore denies them.
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`4
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`Case 1:11-cv-00797-RGA Document 103 Filed 01/06/12 Page 5 of 14 PageID #: 642
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`26.
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`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 26 and therefore denies them.
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`27.
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`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 27 and therefore denies them.
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`28.
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`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 28 and therefore denies them.
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`29.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 29 and therefore denies them.
`
`30.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 30 and therefore denies them.
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`31.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 31 and therefore denies them.
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`32.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 32 and therefore denies them.
`
`33.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 33 and therefore denies them.
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`34.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 34 and therefore denies them.
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`35.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 35 and therefore denies them.
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`36.
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`37.
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`Olympus denies the allegations of Paragraph 36.
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`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 37 and therefore denies them.
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`5
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`Case 1:11-cv-00797-RGA Document 103 Filed 01/06/12 Page 6 of 14 PageID #: 643
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`38.
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`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 38 and therefore denies them.
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`39.
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`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 39 and therefore denies them.
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`40.
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`Olympus is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 40 and therefore denies them.
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`41.
`
`Olympus is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 41 and therefore denies them.
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`PRAYER FOR RELIEF
`
`Olympus denies that FastVDO is entitled to any of the relief requested in its prayer for
`
`relief, or any relief whatsoever. Olympus denies any and all remaining allegations in FastVDO’s
`
`prayer for relief.
`
`Olympus hereby denies each and every allegation in FastVDO’s First Amended
`
`Complaint not expressly admitted above.
`
`AFFIRMATIVE DEFENSES
`
`Olympus asserts the following affirmative defenses without prejudice to its position that
`
`it does not have the burden of proof to establish these defenses to the extent that the burden on
`
`the issue rests with FastVDO as a matter of law.
`
`Olympus hereby gives notice that, in addition to the following affirmative defenses, it
`
`intends to rely upon such other and further defenses as may become available or apparent during
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`pre-trial proceedings in this case and hereby reserves its rights to amend its Answer, if necessary,
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`and to assert such defenses.
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`6
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`
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`Case 1:11-cv-00797-RGA Document 103 Filed 01/06/12 Page 7 of 14 PageID #: 644
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`FIRST AFFIRMATIVE DEFENSE
`(FAILURE TO STATE A CLAIM)
`
`1.
`
`Olympus restates and incorporates by reference all foregoing paragraphs as if set
`
`forth fully herein.
`
`2.
`
`FastVDO has failed to state a claim upon which relief can be granted.
`
`SECOND AFFIRMATIVE DEFENSE
`(INVALIDITY)
`
`3.
`
`Olympus restates and incorporates by reference all foregoing paragraphs as if set
`
`forth fully herein.
`
`4.
`
`All of the claims of the ’081 patent are invalid for failure to comply with one or
`
`more provisions of Title 35 of the United States Code, including without limitation 35 U.S.C.
`
`§§ 101, 102, 103, 112, and/or 120.
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`THIRD AFFIRMATIVE DEFENSE
`(NONINFRINGEMENT)
`
`5.
`
`Olympus restates and incorporates by reference all foregoing paragraphs as if set
`
`forth fully herein.
`
`6.
`
`Olympus is not infringing and has not infringed any valid claim of the ’081
`
`patent, either literally or under the doctrine of equivalents, directly, indirectly, by inducement, or
`
`in any other manner.
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`FOURTH AFFIRMATIVE DEFENSE
`(LACHES, ESTOPPEL, WAIVER)
`
`7.
`
`Olympus restates and incorporates by reference all foregoing paragraphs as if set
`
`forth fully herein.
`
`8.
`
`FastVDO’s claim is barred, in whole or in part, under the doctrine(s) of laches,
`
`estoppel, and/or waiver.
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`7
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`
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`Case 1:11-cv-00797-RGA Document 103 Filed 01/06/12 Page 8 of 14 PageID #: 645
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`FIFTH AFFIRMATIVE DEFENSE
`(ABSOLUTE AND EQUITABLE INTERVENING RIGHTS)
`
`9.
`
`Olympus restates and incorporates by reference all foregoing paragraphs as if set
`
`forth fully herein.
`
`10.
`
`FastVDO’s claims and requested relief are barred in whole or in part by 35 U.S.C.
`
`§ 252 to the extent FastVDO alleges infringement of the ’081 patent by Olympus products
`
`manufactured, used, sold, offered for sale, or imported into the United States, and/or for which
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`substantial preparations were undertaken prior to the date the patent issued or reissued.
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`SIXTH AFFIRMATIVE DEFENSE
`(TIME LIMITATION ON DAMAGES)
`
`11.
`
`Olympus restates and incorporates by reference all foregoing paragraphs as if set
`
`forth fully herein.
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`12.
`
`Olympus is not liable for any damages arising from any alleged infringement of
`
`the ‘081 patent committed more than six years prior to the filing of the Complaint under 35
`
`U.S.C. § 286.
`
`SEVENTH AFFIRMATIVE DEFENSE
`(FAILURE TO MARK)
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`13.
`
`Olympus restates and incorporates by reference all foregoing paragraphs as if set
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`forth fully herein.
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`14.
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`Olympus is not liable for any damages arising from any alleged infringement of
`
`the ‘081 patent before the filing of the Complaint because FastVDO failed to give notice as
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`required by 35 U.S.C. § 287.
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`8
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`Case 1:11-cv-00797-RGA Document 103 Filed 01/06/12 Page 9 of 14 PageID #: 646
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`EIGHTH AFFIRMATIVE DEFENSE
`(COSTS BARRED)
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`15.
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`Olympus restates and incorporates by reference all foregoing paragraphs as if set
`
`forth fully herein.
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`16.
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`FastVDO is barred from recovering costs in connection with this action under 35
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`U.S.C. § 288.
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`NINTH AFFIRMATIVE DEFENSE
`(PROSECUTION HISTORY ESTOPPEL)
`
`17.
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`Olympus restates and incorporates by reference all foregoing paragraphs as if set
`
`forth fully herein.
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`18.
`
`As a result of proceedings before the United States Patent and Trademark Office
`
`during the prosecution of the applications that led to the issuance of the ’081 patent, specifically
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`the admissions, representations, and amendments made on behalf of the applicant, FastVDO is
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`estopped from asserting any construction of the claims of the ’081 patent to cover any activity
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`engaged in or product sold by Olympus.
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`TENTH AFFIRMATIVE DEFENSE
`(IMPROPER JOINDER)
`
`19.
`
`Olympus restates and incorporates by reference all foregoing paragraphs as if set
`
`forth fully herein.
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`20.
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`The claims and named defendants have been improperly joined under Fed. R. Civ.
`
`P. 20 because there are no questions of law and fact common to all of the defendants or the
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`claims do not arise out of the same transaction, occurrence, or series of transactions or
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`occurrences, and therefore the Complaint should be dismissed or, in the alternative, FastVDO’s
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`claims against Olympus should be severed for trial.
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`9
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`Case 1:11-cv-00797-RGA Document 103 Filed 01/06/12 Page 10 of 14 PageID #: 647
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`ELEVENTH AFFIRMATIVE DEFENSE
`(VIOLATION OF REASONABLE AND NON-DISCRIMINATORY LICENSING
`AGREEMENT)
`
`21.
`
`Olympus restates and incorporates by reference all foregoing paragraphs as if set
`
`forth fully herein.
`
`22.
`
`On information and belief, FastVDO has subscribed to subclause 2.2 of the Patent
`
`Policy of the standards setting organization responsible for establishing the H.264/MPEG-4 Part
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`10/Audio Video Coding standard and conditionally agreed to license its technology.
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`Accordingly, FastVDO’s damages are limited by that agreement if and to the extent any damages
`
`are assessed against Olympus.
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`TWELFTH AFFIRMATIVE DEFENSE
`(NO INJUNCTIVE RELIEF)
`
`23.
`
`Olympus restates and incorporates by reference all foregoing paragraphs as if set
`
`forth fully herein.
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`24.
`
`On information and belief, to the extent that FastVDO seeks injunctive relief for
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`any alleged infringement, such relief is barred and unavailable because it is contrary to
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`FastVDO’s commitment to standard-setting organizations to license the ‘081 patent on RAND
`
`terms and Olympus has an irrevocable right to obtain a license by virtue of FastVDO’s RAND
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`commitments.
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`25.
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`In addition, the alleged injury to FastVDO is not immediate or irreparable, and
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`FastVDO has an adequate remedy at law for any alleged injury.
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`PRAYER FOR RELIEF
`
`WHEREFORE, Olympus respectfully requests the following relief:
`
`1.
`
`That the Court dismiss FastVDO’s First Amended Complaint with prejudice and
`
`enter judgment on the First Amended Complaint in favor of Olympus;
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`10
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`Case 1:11-cv-00797-RGA Document 103 Filed 01/06/12 Page 11 of 14 PageID #: 648
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`2.
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`That the Court deny all relief requested by FastVDO in its First Amended
`
`Complaint;
`
`3.
`
`That the Court find this an exceptional case under 35 U.S.C. § 285 and award
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`Olympus the attorneys’ fees, costs and expenses in this action; and
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`4.
`
`That the Court grant to Olympus such other and further relief as this Court deems
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`just and appropriate.
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`JURY DEMAND
`
`Olympus hereby demands a trial by jury of all issues triable of right by a jury.
`
`
`
` YOUNG CONAWAY STARGATT
` & TAYLOR, LLP
`
`
`
` /s/ Pilar G. Kraman
` Adam W. Poff (No. 3990)
`Pilar G. Kraman (No. 5199)
`The Brandywine Building
`1000 West Street, 17th Floor
`Wilmington, DE 19801
`(302) 571-6600
`apoff@ycst.com
`pkraman@ycst.com
`
`Attorneys for Defendant,
`OLYMPUS IMAGING AMERICA
`INC.
`
`11
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`
`
`Of Counsel:
`
`ROPES & GRAY LLP
`J. Steven Baughman
`One Metro Center
`700 12th St. NW Suite 900
`Washington, DC 20005
`(202) 508-4600
`steven.baughman@ropesgray.com
`
`Hiroyuki Hagiwara
`Yusen Building 2F
`3-2 Marunouchi 2-Chome
`Chiyoda-ku, Tokyo 100-0005
`Japan
`81-3-6259-3500
`hiroyuki.hagiwara@ropesgray.com
`
`Dated: January 6, 2012
`
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`
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`Case 1:11-cv-00797-RGA Document 103 Filed 01/06/12 Page 12 of 14 PageID #: 649
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`CERTIFICATE OF SERVICE
`
`
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`I, Pilar G. Kraman, Esquire, hereby certify that on January 6, 2012, I
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`caused to be electronically filed a true and correct copy of the foregoing document with
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`the Clerk of the Court using CM/ECF, which will send notification that such filing is
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`available for viewing and downloading to the following counsel of record:
`
`
`
`Brian E. Farnan, Esquire
`Joseph J. Farnan, Jr., Esquire
`Farnan LLP
`919 North Market Street, 12th Floor
`Wilmington, DE 19801
`bfarnan@farnanlaw.com
`farnan@farnanlaw.com
`
`Thomas Lee Halkowski, Esquire
`Fish & Richardson P.C.
`222 Delaware Avenue, 17th Floor
`Wilmington, DE 19899-1114
`halkowski@fr.com
`
`Frederick L. Cottrell, III, Esquire
`Anne Shea Gaza, Esquire
`Travis Steven Hunter, Esquire
`Richards, Layton & Finger, P.A.
`One Rodney Square
`920 North King Street
`Wilmington, DE 19801
`cottrell@rlf.com
`gaza@rlf.com
`hunter@rlf.com
`
`David E. Moore, Esquire
`Richard L. Horwitz, Esquire
`Potter Anderson & Corroon LLP
`1313 North Market Street
`P.O. Box 951
`Wilmington, DE 19899-0951
`dmoore@potteranderson.com
`rhorwitz@potteranderson.com
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`
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`YCST01:11522022.1
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`
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`070727.1001
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`Case 1:11-cv-00797-RGA Document 103 Filed 01/06/12 Page 13 of 14 PageID #: 650
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`Denise Seastone Kraft, Esquire
`Aleine Michelle Porterfield, Esquire
`DLA Piper LLP
`919 North Market Street, Suite 1500
`Wilmington, DE 19801
`denise.kraft@dlapiper.com
`aleine.porterfield@dlapiper.com
`
`Kenneth L. Dorsney, Esquire
`Morris James LLP
`500 Delaware Avenue, Suite 1500
`Wilmington, DE 19801
`kdorsney@morrisjames.com
`
`Jack B. Blumenfeld, Esquire
`Thomas C. Grimm, Esquire
`Morris Nichols Arsht & Tunnell LLP
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19899-1347
`jblumenfeld@mnat.com
`tgrimm@mnat.com
`
`
`
`John G. Day, Esquire
`Tiffany Geyer Lydon, Esquire
`Ashby & Geddes
`500 Delaware Avenue
`P.O. Box 1150
`Wilmington, DE 19899
`jday@ashby-geddes.com
`tlydon@ashby-geddes.com
`
`Colm F. Connolly Esquire
`Ramy E. Hanna, Esquire
`Morgan Lewis & Bockius LLP
`The Nemours Building
`1007 North Orange Street, Suite 501
`Wilmington, DE 19801
`cconnolly@morganlewis.com
`rhanna@morganlewis.com
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`YCST01:11522022.1
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`2
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`070727.1001
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`Case 1:11-cv-00797-RGA Document 103 Filed 01/06/12 Page 14 of 14 PageID #: 651
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`I further certify that on January 6, 2012, I caused a true and correct copy of the
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`foregoing document to be served by e-mail on the above-listed counsel of record.
`
`YOUNG CONAWAY STARGATT
` & TAYLOR, LLP
`
`/s/ Pilar G. Kraman
`
`Adam W. Poff (No. 3990)
`Pilar G. Kraman (No. 5199)
`The Brandywine Building
`1000 West Street, 17th Floor
`Wilmington, Delaware 19801
`pkraman@ycst.com
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`YCST01:11522022.1
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`070727.1001
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