Case 1:11-cv-00797-RGA Document 123 Filed 03/19/12 Page 1 of 17 PageID #: 804
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 11-797-RGA
`
`JURY TRIAL DEMANDED
`
`)))))))))
`
`FASTVDO LLC,
`
`Plaintiff,
`
`v.
`
`APPLE INC., et al.,
`
`Defendants.
`
`SAMSUNG ELECTRONICS AMERICA, INC.’S ANSWER, DEFENSES AND
`COUNTERCLAIMS TO PLAINTIFF’S FIRST AMENDED COMPLAINT
`
`COMES NOW defendant Samsung Electronics America, Inc. (“Samsung”), and for its
`
`Answer, Defenses and Counterclaims to the First Amended Complaint of plaintiff FastVDO
`
`LLC (“FastVDO”), admits, denies and alleges as follows:
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`PARTIES
`
`1.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 1 and on that basis denies each and every allegation
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`contained therein.
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`2.
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`Samsung 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 on that basis denies each and every allegation
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`contained therein.
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`3.
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`Samsung 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 on that basis denies each and every allegation
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`contained therein.
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`4.
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`Samsung 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 on that basis denies each and every allegation
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`contained therein.
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 11-797-RGA
`
`JURY TRIAL DEMANDED
`
`)))))))))
`
`FASTVDO LLC,
`
`Plaintiff,
`
`v.
`
`APPLE INC., et al.,
`
`Defendants.
`
`SAMSUNG ELECTRONICS AMERICA, INC.’S ANSWER, DEFENSES AND
`COUNTERCLAIMS TO PLAINTIFF’S FIRST AMENDED COMPLAINT
`
`COMES NOW defendant Samsung Electronics America, Inc. (“Samsung”), and for its
`
`Answer, Defenses and Counterclaims to the First Amended Complaint of plaintiff FastVDO
`
`LLC (“FastVDO”), admits, denies and alleges as follows:
`
`PARTIES
`
`1.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 1 and on that basis denies each and every allegation
`
`contained therein.
`
`2.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 2 and on that basis denies each and every allegation
`
`contained therein.
`
`3.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 3 and on that basis denies each and every allegation
`
`contained therein.
`
`4.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 4 and on that basis denies each and every allegation
`
`contained therein.
`
`
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`Case 1:11-cv-00797-RGA Document 123 Filed 03/19/12 Page 2 of 17 PageID #: 805
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`5.
`
`Samsung 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 on that basis denies each and every allegation
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`contained therein.
`
`6.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 6 and on that basis denies each and every allegation
`
`contained therein.
`
`7.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 7 and on that basis denies each and every allegation
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`contained therein.
`
`8.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 8 and on that basis denies each and every allegation
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`contained therein.
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`9.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 9 and on that basis denies each and every allegation
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`contained therein.
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`10.
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`Samsung is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 10 and on that basis denies each and every allegation
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`contained therein.
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`11.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 11 and on that basis denies each and every allegation
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`contained therein.
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`- 2 -
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`Case 1:11-cv-00797-RGA Document 123 Filed 03/19/12 Page 3 of 17 PageID #: 806
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`12.
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`Samsung 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 on that basis denies each and every allegation
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`contained therein.
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`13.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 13 and on that basis denies each and every allegation
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`contained therein.
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`14.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 14 and on that basis denies each and every allegation
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`contained therein.
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`15.
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`Samsung 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 on that basis denies each and every allegation
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`contained therein.
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`16.
`
`In answer to paragraph 16, Samsung admits that it is a New York corporation.
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`Samsung denies that its principal place of business is located at 105 Challenger Road, Ridgefield
`
`Park, NJ 07660. Samsung’s principal place of business is located at 85 Challenger Road,
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`Ridgefield Park, NJ 07660.
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`17.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 17 and on that basis denies each and every allegation
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`contained therein.
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`18.
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`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 18 and on that basis denies each and every allegation
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`contained therein.
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`- 3 -
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`Case 1:11-cv-00797-RGA Document 123 Filed 03/19/12 Page 4 of 17 PageID #: 807
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`19.
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`Samsung 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 on that basis denies each and every allegation
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`contained therein.
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`20.
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`Samsung is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations in Paragraph 20 and on that basis denies each and every allegation
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`contained therein.
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`JURISDICTION AND VENUE
`
`21.
`
`Samsung admits that FastVDO purports to bring a patent infringement action
`
`pursuant to Title 35 of the United States Code, including § 271. Samsung admits that the Court
`
`has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).
`
`22.
`
`Samsung admits that this Court has personal jurisdiction over Samsung. Except
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`as expressly admitted herein, Samsung denies each and every allegation set forth in Paragraph
`
`22.
`
`23.
`
`Samsung admits that venue is proper in the District of Delaware under 28 U.S.C.
`
`§§ 1391(b)-(c) and 1400(b), although Samsung expressly reserves the right to contest whether
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`the District of Delaware is a convenient forum under, among others, the doctrine of forum non
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`conveniens. Except as expressly admitted herein, Samsung denies each and every allegation set
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`forth in Paragraph 23.
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`COUNT 1
`
`24.
`
`Samsung admits that U.S. Patent No. RE 40,081 (“the patent-in-suit”), titled “Fast
`
`Signal Transforms With Lifting Steps” was reissued on February 19, 2008, and that what appears
`
`to be a copy was attached to the Complaint as Exhibit A. Except as expressly admitted or denied
`
`herein, Samsung is without knowledge or information sufficient to form a belief as to the truth of
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`- 4 -
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`Case 1:11-cv-00797-RGA Document 123 Filed 03/19/12 Page 5 of 17 PageID #: 808
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`the remaining allegations in Paragraph 24 and on that basis denies each and every allegation
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`contained therein.
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`25.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 25 and on that basis denies each and every allegation
`
`contained therein.
`
`26.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 26 and on that basis denies each and every allegation
`
`contained therein.
`
`27.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 27 and on that basis denies each and every allegation
`
`contained therein.
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`28.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 28 and on that basis denies each and every allegation
`
`contained therein.
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`29.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 29 and on that basis denies each and every allegation
`
`contained therein.
`
`30.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 30 and on that basis denies each and every allegation
`
`contained therein.
`
`31.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 31 and on that basis denies each and every allegation
`
`contained therein.
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`- 5 -
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`Case 1:11-cv-00797-RGA Document 123 Filed 03/19/12 Page 6 of 17 PageID #: 809
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`32.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 32 and on that basis denies each and every allegation
`
`contained therein.
`
`33.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 33 and on that basis denies each and every allegation
`
`contained therein.
`
`34.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 34 and on that basis denies each and every allegation
`
`contained therein.
`
`35.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 35 and on that basis denies each and every allegation
`
`contained therein.
`
`36.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 36 and on that basis denies each and every allegation
`
`contained therein.
`
`37.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 37 and on that basis denies each and every allegation
`
`contained therein.
`
`38.
`
`Samsung denies each and every allegation contained in Paragraph 38, and
`
`specifically denies that it has infringed or is infringing, or has induced or is inducing anyone else
`
`to infringe, any valid claim of the patent-in-suit.
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`- 6 -
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`Case 1:11-cv-00797-RGA Document 123 Filed 03/19/12 Page 7 of 17 PageID #: 810
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`39.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 39 and on that basis denies each and every allegation
`
`contained therein.
`
`40.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 40 and on that basis denies each and every allegation
`
`contained therein.
`
`41.
`
`Samsung is without knowledge or information sufficient to form a belief as to the
`
`truth of the allegations in Paragraph 41 and on that basis denies each and every allegation
`
`contained therein.
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`PRAYER FOR RELIEF
`
`42.
`
`In response to FastVDO’s prayer for relief, Samsung denies each and every
`
`allegation contained therein and, further, Samsung specifically denies that FastVDO is entitled to
`
`any of the relief requested in the Complaint; specifically denies that FastVDO is entitled to a
`
`judgment that Samsung has infringed any valid claim of the patent-in-suit, literally or under the
`
`doctrine of equivalents; specifically denies that FastVDO is entitled to a judgment that Samsung
`
`has induced the infringement of any valid claim of the patent-in-suit; specifically denies that
`
`FastVDO is entitled to any injunctive relief; specifically denies that FastVDO is entitled to any
`
`award of damages; specifically denies that FastVDO is entitled to reasonable attorneys’ fees; and
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`specifically denies that FastVDO is entitled to a judgment requiring Samsung to pay FastVDO
`
`supplemental damages, including pre-judgment and post-judgment interest, or any other relief in
`
`this action.
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`- 7 -
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`Case 1:11-cv-00797-RGA Document 123 Filed 03/19/12 Page 8 of 17 PageID #: 811
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`DEFENSES OF DEFENDANT SAMSUNG
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`43.
`
`Samsung alleges the following separate defenses to the Complaint. By virtue of
`
`having listed the following defenses, Samsung does not assume any legal or factual burden not
`
`otherwise assigned to it under the law.
`
`FIRST DEFENSE
`
`44.
`
`Samsung has not infringed and is not infringing any valid and enforceable claim
`
`of the patent-in-suit directly, indirectly, contributorily, or by inducement.
`
`SECOND DEFENSE
`
`45.
`
`The claims of the patent-in-suit are invalid for failure to comply with one or more
`
`of the requirements of Title 35, United States Code, including without limitation §§ 101, 102,
`
`103, 111, 112, 116, 132, and/or 251.
`
`THIRD DEFENSE
`
`46.
`
`FastVDO’s enforcement of the patent-in-suit is limited, in whole or in part, by the
`
`doctrine of prosecution history estoppel.
`
`FOURTH DEFENSE
`
`47.
`
`FastVDO’s claims are barred, in whole or in part, by the equitable doctrines of
`
`laches, estoppel, waiver, acquiescence, implied license, and/or unclean hands.
`
`FIFTH DEFENSE
`
`48.
`
`FastVDO is not entitled to an injunction because FastVDO is not likely to prevail
`
`on the merits, has not suffered and will not suffer irreparable harm because of Samsung’s
`
`conduct, and has an adequate remedy at law.
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`- 8 -
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`Case 1:11-cv-00797-RGA Document 123 Filed 03/19/12 Page 9 of 17 PageID #: 812
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`SIXTH DEFENSE
`
`49.
`
`FastVDO’s claim for damages, if any, against Samsung for alleged infringement
`
`of the patent-in-suit is limited by 35 U.S.C. §§ 286, 287, and/or 288.
`
`SEVENTH DEFENSE
`
`50.
`
`FastVDO’s claims for relief are limited by the doctrines of full compensation,
`
`exhaustion, and/or first sale, and FastVDO is not entitled to double recovery.
`
`RESERVATION OF ADDITIONAL DEFENSES
`
`51.
`
`Samsung reserves the right to assert additional defenses that may be developed
`
`through discovery in this action.
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`COUNTERCLAIMS OF DEFENDANT AND COUNTERCLAIMANT SAMSUNG
`
`For its counterclaims against FastVDO, Defendant and Counterclaimant Samsung alleges
`
`as follows:
`
`NATURE AND BASIS OF THE ACTION
`
`1.
`
`The Court has jurisdiction to declare the rights and interests of the parties related
`
`to these counterclaims for declaratory judgment of patent non-infringement under 28 U.S.C. §§
`
`2201 and 2202.
`
`JURISDICTION AND PARTIES
`
`2.
`
`The Court has subject matter jurisdiction over this controversy under 28 U.S.C.
`
`§§ 1331 and 1338(a).
`
`3.
`
`Samsung Electronics America, Inc. is a corporation with its principal place of
`
`business at 85 Challenger Road, Ridgefield Park, NJ 07660.
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`- 9 -
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`Case 1:11-cv-00797-RGA Document 123 Filed 03/19/12 Page 10 of 17 PageID #: 813
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`4.
`
`Samsung is informed and believes that Plaintiff and Counterdefendant FastVDO
`
`LLC (“FastVDO”) is a limited liability company organized under the laws of Florida with a
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`principal place of business at 750 N. Atlantic Ave., Cocoa Beach, FL, 32931.
`
`5.
`
`Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(b)-(c) and
`
`1400(b).
`
`6.
`
`7.
`
`FIRST COUNTERCLAIM FOR RELIEF
`(For Declaratory Judgment of Non-Infringement of the Patent-In-Suit)
`
`Samsung incorporates the foregoing admissions, denials, and allegations.
`
`There exists an actual and justiciable controversy within the meaning of 28 U.S.C.
`
`§§ 2201 and 2202 between Samsung and FastVDO with respect to the alleged infringement of
`
`the patent-in-suit.
`
`8.
`
`By this Counterclaim, Samsung seeks a declaration that it has not infringed and
`
`does not infringe any valid and enforceable claim of the patent-in-suit either literally or under the
`
`doctrine of equivalents. Further, Samsung seeks a declaration that it has not contributed to nor
`
`induced and does not contribute to nor induce infringement of the patent-in-suit by anyone. A
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`judicial declaration is necessary and appropriate at this time in order that Samsung may ascertain
`
`its right and duties with respect to the patent-in-suit and with respect to any past, present, or
`
`future manufacture, use, importation, distribution, sale, or offer for sale of its products.
`
`SECOND COUNTERCLAIM FOR RELIEF
`(For Declaratory Judgment of Invalidity of the Patent-In-Suit)
`
`Samsung incorporates the foregoing admissions, denials, and allegations.
`
`There exists an actual and justiciable controversy within the meaning of 28 U.S.C.
`
`9.
`
`10.
`
`§§ 2201 and 2202 between Samsung and FastVDO with respect to the validity of the patent-in-
`
`suit.
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`- 10 -
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`Case 1:11-cv-00797-RGA Document 123 Filed 03/19/12 Page 11 of 17 PageID #: 814
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`11.
`
`An actual controversy exists between Samsung and FastVDO as to whether the
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`patent-in-suit is valid, as FastVDO contends, or is invalid for failure to comply with the
`
`requirements of patentability set forth in 35 U.S.C. §§ 101, 102, 103, 111, 112, 116, 132 and/or
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`251, as Samsung contends.
`
`12.
`
`By this Counterclaim, Samsung seeks a declaration that the claims of the patent-
`
`in-suit are invalid. A judicial declaration is necessary and appropriate at this time in order that
`
`Samsung may ascertain its right and duties with respect to the patent-in-suit and to any past,
`
`present, or future manufacture, use, importation, distribution, sale, or offer for sale of its
`
`products.
`
`REQUEST FOR JURY TRIAL
`
`13.
`
`Samsung hereby requests a trial by jury of all issues in this Action.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Defendant and Counterclaimant Samsung prays that:
`
`(1)
`
`the Court dismiss with prejudice the Complaint, that FastVDO take nothing by
`
`reason of the Complaint, and that judgment be rendered in favor of Samsung;
`
`(2)
`
`the Court render judgment declaring that Samsung has not infringed, contributed
`
`to the infringement of, or induced others to infringe, either directly or indirectly, any valid or
`
`enforceable claim of the patent-in-suit;
`
`(3)
`
`the Court render judgment declaring that the claims of the patent-in-suit are
`
`invalid and/or unenforceable;
`
`the Court declare this an exceptional case under 35 U.S.C. § 285;
`
`Samsung be awarded its fees and costs, including attorneys’ fees incurred herein;
`
`(4)
`
`(5)
`
`and
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`- 11 -
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`Case 1:11-cv-00797-RGA Document 123 Filed 03/19/12 Page 12 of 17 PageID #: 815
`
`(6)
`
`the Court grant Samsung such other and further relief as it deems proper.
`
`OF COUNSEL:
`
`Ryan Yagura
`O’MELVENY & MYERS LLP
`400 South Hope Street
`Los Angeles, CA 90071-2899
`Tel: (213) 430-6000
`
`Kristopher Dawes
`O’MELVENY & MYERS LLP
`610 Newport Center Drive, 17th Floor
`Newport Beach, CA 92660
`Tel: (949) 760-9600
`
`Dated: March 19, 2012
`1051772 / 38795
`
`Respectfully submitted,
`
`POTTER ANDERSON & CORROON LLP
`
`By:
`
`/s/ Richard L. Horwitz
`Richard L. Horwitz (#2246)
`David E. Moore (#3983)
`Hercules Plaza, 6th Floor
`1313 N. Market Street
`Wilmington, DE 19801
`Tel: (302) 984-6000
`rhorwitz@potteranderson.com
`dmoore@potteranderson.com
`
`Attorneys for Defendant
`Samsung Electronics America Inc.
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`- 12 -
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`Case 1:11-cv-00797-RGA Document 123 Filed 03/19/12 Page 13 of 17 PageID #: 816
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`CERTIFICATE OF SERVICE
`
`I, Richard L. Horwitz, hereby certify that on March 19, 2012, the attached document was
`
`electronically filed with the Clerk of the Court using CM/ECF which will send notification to the
`
`registered attorney(s) of record that the document has been filed and is available for viewing and
`
`downloading.
`
`I further certify that on March 19, 2012, the attached document was Electronically
`
`Mailed to the following person(s):
`
`Joseph J. Farnan , Jr.
`Brian E. Farnan
`Farnan LLP
`919 North Market Street, 12th Floor
`Wilmington, DE 19801
`farnan@farnanlaw.com
`bfarnan@farnanlaw.com
`Attorneys for Plaintiff FastVDO LLC
`
`Thomas L. Halkowski
`Fish & Richardson, P.C.
`222 Delaware Avenue, 17th Floor
`Wilmington, DE 19899-1114
`halkowski@fr.com
`Attorneys for Defendant Apple Inc.
`
`Kelly C. Hunsaker
`Thomas B. Manuel
`Fish & Richardson P.C.
`500 Arguello Street, Suite 500
`Redwood City, CA 94063
`hunsaker@fr.com
`manuel@fr.com
`Attorneys for Defendant Apple Inc.
`
`Marc A. Fenster
`Alexander C.D. Giza
`Kevin P. Burke
`Russ, August & Kabat
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, CA 90025-1031
`mfenster@raklaw.com
`agiza@raklaw.com
`kburke@raklaw.com
`Attorneys for Plaintiff FastVDO LLC
`
`Juanita R. Brooks
`Fish & Richardson P.C.
`12390 El Camino Real
`San Diego, CA 92130
`brooks@fr.com
`Attorneys for Defendant Apple Inc.
`
`Richard A. Sterba
`Fish & Richardson P.C.
`1425 K Street, NW, 11th Floor
`Washington, DC 20005
`sterba@fr.com
`Attorneys for Defendant Apple Inc.
`
`
`
`Case 1:11-cv-00797-RGA Document 123 Filed 03/19/12 Page 14 of 17 PageID #: 817
`
`Frederick L. Cottrell, III
`Anne Shea Gaza
`Travis S. Hunter
`Richards, Layton & Finger, PA
`One Rodney Square
`920 N. King Street
`Wilmington, DE 19801
`cottrell@rlf.com
`gaza@rlf.com
`hunter@rlf.com
`Attorneys for Defendant Canon U.S.A. Inc.
`
`Scott D. Stimpson
`Katherine M. Lieb
`David C. Lee
`SILLS CUMMIS & GROSS P.C.
`30 Rockefeller Plaza
`New York, NY 10112
`sstimpson@sillscummis.com
`klieb@sillscummis.com
`dlee@sillscummis.com
`Attorneys for Defendant Casio America, Inc.
`
`Joseph A. Calvaruso
`Richard F. Martinelli
`Rodger A. Sadler
`Orrick, Herrington & Sutcliffe LLP
`51 W. 52nd Street
`New York, NY 10019-6142
`jcalvaruso@orrick.com
`rmartinelli@orrick.com
`rsadler@orrick.com
`Attorneys for Defendant Canon U.S.A. Inc.
`
`John G. Day
`Tiffany Geyer Lydon
`Andrew C. Mayo
`Ashby & Geddes
`500 Delaware Avenue, 8th Floor
`P. O. Box 1150
`Wilmington, DE 19899
`jday@ashby-geddes.com
`tlydon@ashby-geddes.com
`amay@ashby-geddes.com
`Attorneys for Defendants DXG Technology
`USA, Inc., Fujifilm North America
`Corporation, Nikon Americas Inc., Nikon Inc.
`and Panasonic Corporation of North America
`
`Brian E. Mitchell
`Jigang Jin
`Mitchell + Company, Law Offices
`4 Embarcadero Center, Suite 1400
`San Francisco, CA 94111
`brian.mitchell@mcolawoffices.com
`jigang.jin@mcolawoffices.com
`Attorneys for Defendant DXG Technology
`USA, Inc.,
`
`Denise Seastone Kraft
`Aleine Porterfield
`DLA Piper LLP
`919 N. Market Street, Suite 1500
`Wilmington, DE 19801
`denise.kraft@dlapiper.com
`aleine.porterfield@dlapiper.com
`Attorneys for Defendant Eastman Kodak
`Company
`
`2
`
`
`
`Case 1:11-cv-00797-RGA Document 123 Filed 03/19/12 Page 15 of 17 PageID #: 818
`
`Sean C. Cunningham
`John D. Kinton
`David R. Knudson
`DLA Piper (US) LLP
`401 B Street, Suite 1700
`San Diego, CA 92101
`sean.cunningham@dlapiper.com
`john.kinton@dlapiper.com
`david.knudson@dlapiper.com
`Attorneys for Defendant Eastman Kodak
`Company
`
`Colm F. Connolly
`Ramy E. Hanna
`Morgan Lewis & Bockius LLP
`1007 Orange Street, Suite 501
`Wilmington, DE 19801
`cconnolly@morganlewis.com
`rhanna@morganlewis.com
`Attorneys for Defendant Hewlett Packard
`Company
`
`Kenneth L. Dorsney
`Morris James LLP
`500 Delaware Avenue, Suite 1500
`Wilmington, DE 19899-2306
`kdorsney@morrisjames.com
`Attorneys for Defendant JVC Americas
`Corporation
`
`Steven J. Routh
`Sten A. Jensen
`William H. Wright
`John R. Inge
`T. Vann Pearce, Jr.
`Orrick, Herrington & Sutcliffe LLP
`1152 15th Street, N.W.
`Washington, DC 20005-1706
`srouth@orrick.com
`sjensen@orrick.com
`wwright@orrick.com
`jinge@orrick.com
`Attorneys for Defendants Fujifilm North
`America Corporation, Nikon Americas Inc.,
`Nikon Inc. and Panasonic Corporation of
`North America
`
`Mark W. Taylor
`Morgan, Lewis & Bockius, LLP
`1111 Pennsylvania Ave., NW
`Washington, DC 20004
`Mark.taylor@morganlewis.com
`Attorneys for Defendant Hewlett Packard
`Company
`
`Michael J. Kasdan
`Abraham Kasdan, Ph.D.
`Anthony F. Lo Cicero
`Samuel Lo
`Amster Rothstein & Ebenstein LLP
`90 Park Avenue, 21st Floor
`New York, NY 10016
`mkasdan@arelaw.com
`akasdan@arelaw.com
`alocicero@arelaw.com
`slo@arelaw.com
`Attorneys for Defendant JVC Americas
`Corporation
`
`3
`
`
`
`Case 1:11-cv-00797-RGA Document 123 Filed 03/19/12 Page 16 of 17 PageID #: 819
`
`Karen Jacobs Louden
`Jennifer Ying
`Morris, Nichols, Arsht & Tunnell LLP
`1201 North Market Street
`Wilmington, DE 19899
`klouden@mnat.com
`jying@mnat.com
`Attorneys for Defendant Lite-On Sales and
`Distribution Inc.
`
`Adam W. Poff
`Pilar G. Kraman
`Young, Conaway, Stargatt & Taylor LLP
`Rodney Square
`1000 North King Street
`Wilmington, DE 19801
`apoff@ycst.com
`pkraman@ycst.com
`Attorneys for Defendant Olympus Imaging
`America Inc.
`
`Eric T. Syu
`Deborah S. Katz
`Ropes & Gray LLP
`1211 Avenue of the Americas
`New York, NY 10036
`eric.syu@ropesgray.com
`deborah.katz@ropesgray.com
`Attorneys for Defendant Olympus Imaging
`America Inc.
`
`Andrew Shupe
`Dariush G. Adli
`Raymond K. Chan
`ADLI Law Group P.C.
`633 West Fifth Street, Suite 6900
`Los Angeles, CA 90071
`andrew.shupe@adlilaw.com
`adli@adlilaw.com
`raymond.chan@adlilaw.com
`Attorneys for Defendant Lite-On Sales and
`Distribution Inc.
`
`J. Steven Baughman
`Ropes & Gray LLP
`One Metro Center
`700 12th Street, NW, Suite 900
`Washington, DC 20005
`steven.baughman@ropesgray.com
`Attorneys for Defendant Olympus America
`Inc.
`
`Hiroyuki Hagiwara
`Ropes & Gray LLP
`Yusen Building 2F 3-2 Marunouchi 2-Chome
`Chiyoda-ku
`Tokyo, Japan 100-0005
`hiroyuki.hagiwara@ropesgray.com
`Attorneys for Defendant Olympus Imaging
`America Inc.
`
`Ryan Yagura
`O’Melveny & Myers LLP
`400 South Hope Street
`Los Angeles, CA 90071-2899
`ryagura@omm.com
`Attorneys for Defendant Samsung Electronics
`America Inc.
`
`Kristopher Dawes
`O’Melveny & Myers LLP
`610 Newport Center Drive, 17th Floor
`Newport Beach, CA 92660
`kdawes@omm.com
`Attorneys for Defendant Samsung Electronics
`America Inc.
`
`4
`
`
`
`Case 1:11-cv-00797-RGA Document 123 Filed 03/19/12 Page 17 of 17 PageID #: 820
`
`Jack B. Blumenfeld
`Morris, Nichols, Arsht & Tunnell LLP
`1201 North Market Street
`Wilmington, DE 19899
`jblumenfeld@mnat.com
`Attorneys for Defendants Sony Corporation of
`America and Sony Electronics Inc.
`
`Thomas C. Grimm
`Morris, Nichols, Arsht & Tunnell LLP
`1201 North Market Street
`Wilmington, DE 19899
`tgrimm@mnat.com
`Attorneys for Defendant Toshiba America Inc.
`
`Michael A. Dorfman
`Timothy J. Vezeau
`Dennis C. Lee
`Katten Muchin Rosenman LLP
`525 W. Monroe Street
`Chicago, IL 60661-3693
`USR-FRM-Sanyo-FastVDO@kattenlaw.com
`Attorneys for Defendant Sanyo North America
`Corporation
`
`Lewis V. Popovski
`Michelle Carniaux
`Kenyon & Kenyon LLP
`One Broadway
`New York, NY 10004-1007
`lpopovski@kenyon.com
`mcarniaux@kenyon.com
`Attorneys for Defendants Sony Corporation of
`America and Sony Electronics Inc.
`
`Jeffrey H. Nelson
`Michael J. Shea
`Jonathan T. Reavill
`Nixon Vanderhye P.C.
`901 North Glebe Road, 11th Floor
`Arlington, VA 22203
`jhn@nixonvan.com
`mjs@nixonvan.com
`jtr@nixonvan.com
`Attorneys for Defendant Toshiba America
`Information Systems, Inc.
`
`By:
`
`/s/ Richard L. Horwitz
`Richard L. Horwitz
`David E. Moore
`POTTER ANDERSON & CORROON LLP
`Tel: (302) 984-6000
`rhorwitz@potteranderson.com
`dmoore@potteranderson.com
`
`1031860/37314/37364/38795
`
`5
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