throbber
Case 1:11-cv-00797-RGA Document 69 Filed 11/17/11 Page 1 of 13 PageID #: 359
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`
`FastVDO LLC,
`
`
`
`C.A. No. 11-cv-00797 (PD)
`
`
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`
`
`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 America Inc.;
`Panasonic Corporation of North America;
`Samsung Electronics America;
`Sanyo North America Corporation;
`Sony Corporation of America, Inc.;
`Sony Electronics, Inc.; and
`Toshiba America, Inc.;
`
`
`
`
`
`
`
`Defendants.
`
`APPLE INC.’S ANSWER, AFFIRMATIVE DEFENSES AND COUNTERCLAIMS TO
`PLAINTIFF FASTVDO LLC’S FIRST AMENDED COMPLAINT
`
`Defendant Apple Inc. (“Apple”) hereby sets forth its Answer, Affirmative Defenses and
`
`
`
`
`
`
`
`
`
`Counterclaims to Plaintiff FastVDO LLC’s (“FastVDO”) First Amended Complaint, filed
`
`October 31, 2011, as follows:
`
`ANSWER TO FIRST AMENDED COMPLAINT
`
`Responding to the individually enumerated paragraphs of the First Amended Complaint,
`
`Apple states as follows:
`
`

`
`Case 1:11-cv-00797-RGA Document 69 Filed 11/17/11 Page 2 of 13 PageID #: 360
`
`PARTIES
`
`1.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 1 of the First Amended Complaint, and therefore denies
`
`them.
`
`2.
`
`Apple admits that it is incorporated under the laws of the state of California and has
`
`a place of business at 1 Infinite Loop, Cupertino, California 95014.
`
`3.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 3 of the First Amended Complaint, and therefore denies
`
`them.
`
`4.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 4 of the First Amended Complaint, and therefore denies
`
`them.
`
`5.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 5 of the First Amended Complaint, and therefore denies
`
`them.
`
`6.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 6 of the First Amended Complaint, and therefore denies
`
`them.
`
`7.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 7 of the First Amended Complaint, and therefore denies
`
`them.
`
`8.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 8 of the First Amended Complaint, and therefore denies
`
`them.
`
`
`
`2
`
`
`
`

`
`Case 1:11-cv-00797-RGA Document 69 Filed 11/17/11 Page 3 of 13 PageID #: 361
`
`9.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 9 of the First Amended Complaint, and therefore denies
`
`them.
`
`10.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 10 of the First Amended Complaint, and therefore denies
`
`them.
`
`11.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 11 of the First Amended Complaint, and therefore denies
`
`them.
`
`12.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 12 of the First Amended Complaint, and therefore denies
`
`them.
`
`13.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 13 of the First Amended Complaint, and therefore denies
`
`them.
`
`14.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 14 of the First Amended Complaint, and therefore denies
`
`them.
`
`15.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 15 of the First Amended Complaint, and therefore denies
`
`them.
`
`16.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 16 of the First Amended Complaint, and therefore denies
`
`them.
`
`
`
`3
`
`
`
`

`
`Case 1:11-cv-00797-RGA Document 69 Filed 11/17/11 Page 4 of 13 PageID #: 362
`
`17.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 17 of the First Amended Complaint, and therefore denies
`
`them.
`
`18.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 18 of the First Amended Complaint, and therefore denies
`
`them.
`
`19.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 19 of the First Amended Complaint, and therefore denies
`
`them.
`
`20.
`
`Apple lacks knowledge or information sufficient to form a belief as to the truth of
`
`the allegations contained in Paragraph 20 of the First Amended Complaint, and therefore denies
`
`them.
`
`JURISDICTION AND VENUE
`
`21.
`
`Apple admits that FastVDO has made a claim of patent infringement under Title 35
`
`and that this Court has jurisdiction over the subject matter of this action under 28 U.S.C. §§ 1331
`
`and 1338(a). Except as expressly admitted, Apple denies the remaining allegations in
`
`Paragraph 21 of the First Amended Complaint.
`
`22.
`
`Apple admits that it is subject to the personal jurisdiction of this Court. Apple
`
`denies that it has committed any act of infringement. To the extent the allegations of Paragraph 22
`
`relate to other defendants, Apple lacks knowledge sufficient to admit or deny the allegations and
`
`on that basis denies them. Except as expressly admitted, Apple denies the remaining allegations
`
`contained in Paragraph 22 of the First Amended Complaint.
`
`23.
`
`Apple admits that venue in this District is proper under 28 U.S.C. §§ 1391(c) and
`
`1400(b) and that it is subject to the personal jurisdiction of this Court, but denies that this judicial
`
`
`
`4
`
`
`
`

`
`Case 1:11-cv-00797-RGA Document 69 Filed 11/17/11 Page 5 of 13 PageID #: 363
`
`district is the most convenient forum for the parties and witnesses or in the interests of justice.
`
`Apple further denies that it has committed any act of infringement. To the extent the allegations
`
`of Paragraph 23 relate to other defendants, Apple lacks knowledge sufficient to admit or deny the
`
`allegations and on that basis denies them. Except as expressly admitted, Apple denies the
`
`remaining allegations contained in Paragraph 23 of the First Amended Complaint.
`
`COUNT I
`(Infringement of U.S. Patent No. RE40,081)
`
`24.
`
`Apple admits that a copy of U.S. Reissued Patent No. RE40,081 (“the ’081 Patent”)
`
`is attached as Exhibit A to the First Amended Complaint. Apple further admits that U.S. Reissued
`
`Patent No. RE40,081 states on its face that: (a) it is entitled “Fast Signal Transforms With Lifting
`
`Steps” and (b) it was reissued on February 19, 2008. Except as expressly admitted, and to the
`
`extent any response is required, the remaining factual allegations contained in Paragraph 24 of the
`
`First Amended Complaint are denied.
`
`25.
`
`26.
`
`Denied.
`
`Paragraph 26 does not require a response by Apple. To the extent that
`
`Paragraph 26 is deemed to require a response, Apple lacks knowledge sufficient to confirm or
`
`deny the allegations of Paragraph 26, and therefore denies them.
`
`27.
`
`Paragraph 27 does not require a response by Apple. To the extent that
`
`Paragraph 27 is deemed to require a response, Apple lacks knowledge sufficient to confirm or
`
`deny the allegations of Paragraph 27, and therefore denies them.
`
`28.
`
`Paragraph 28 does not require a response by Apple. To the extent that
`
`Paragraph 28 is deemed to require a response, Apple lacks knowledge sufficient to confirm or
`
`deny the allegations of Paragraph 28, and therefore denies them.
`
`
`
`5
`
`
`
`

`
`Case 1:11-cv-00797-RGA Document 69 Filed 11/17/11 Page 6 of 13 PageID #: 364
`
`29.
`
`Paragraph 29 does not require a response by Apple. To the extent that
`
`Paragraph 29 is deemed to require a response, Apple lacks knowledge sufficient to confirm or
`
`deny the allegations of Paragraph 29, and therefore denies them.
`
`30.
`
`Paragraph 30 does not require a response by Apple. To the extent that
`
`Paragraph 30 is deemed to require a response, Apple lacks knowledge sufficient to confirm or
`
`deny the allegations of Paragraph 30, and therefore denies them.
`
`31.
`
`Paragraph 31 does not require a response by Apple. To the extent that
`
`Paragraph 31 is deemed to require a response, Apple lacks knowledge sufficient to confirm or
`
`deny the allegations of Paragraph 31, and therefore denies them.
`
`32.
`
`Paragraph 32 does not require a response by Apple. To the extent that
`
`Paragraph 32 is deemed to require a response, Apple lacks knowledge sufficient to confirm or
`
`deny the allegations of Paragraph 32, and therefore denies them.
`
`33.
`
`Paragraph 33 does not require a response by Apple. To the extent that
`
`Paragraph 33 is deemed to require a response, Apple lacks knowledge sufficient to confirm or
`
`deny the allegations of Paragraph 33, and therefore denies them.
`
`34.
`
`Paragraph 34 does not require a response by Apple. To the extent that
`
`Paragraph 34 is deemed to require a response, Apple lacks knowledge sufficient to confirm or
`
`deny the allegations of Paragraph 34, and therefore denies them.
`
`35.
`
`Paragraph 35 does not require a response by Apple. To the extent that
`
`Paragraph 35 is deemed to require a response, Apple lacks knowledge sufficient to confirm or
`
`deny the allegations of Paragraph 35, and therefore denies them.
`
`36.
`
`Paragraph 36 does not require a response by Apple. To the extent that
`
`Paragraph 36 is deemed to require a response, Apple lacks knowledge sufficient to confirm or
`
`deny the allegations of Paragraph 36, and therefore denies them.
`
`
`
`6
`
`
`
`

`
`Case 1:11-cv-00797-RGA Document 69 Filed 11/17/11 Page 7 of 13 PageID #: 365
`
`37.
`
`Paragraph 37 does not require a response by Apple. To the extent that
`
`Paragraph 37 is deemed to require a response, Apple lacks knowledge sufficient to confirm or
`
`deny the allegations of Paragraph 37, and therefore denies them.
`
`38.
`
`Paragraph 38 does not require a response by Apple. To the extent that
`
`Paragraph 38 is deemed to require a response, Apple lacks knowledge sufficient to confirm or
`
`deny the allegations of Paragraph 38, and therefore denies them.
`
`39.
`
`Paragraph 39 does not require a response by Apple. To the extent that
`
`Paragraph 39 is deemed to require a response, Apple lacks knowledge sufficient to confirm or
`
`deny the allegations of Paragraph 39, and therefore denies them.
`
`40.
`
`Paragraph 40 does not require a response by Apple. To the extent that
`
`Paragraph 40 is deemed to require a response, Apple lacks knowledge sufficient to confirm or
`
`deny the allegations of Paragraph 40, and therefore denies them.
`
`41.
`
`Paragraph 41 does not require a response by Apple. To the extent that
`
`Paragraph 41 is deemed to require a response, Apple lacks knowledge sufficient to confirm or
`
`deny the allegations of Paragraph 41, and therefore denies them.
`
`GENERAL DENIAL
`
`
`
`Except as specifically admitted, Apple denies each and every allegation contained in
`
`Paragraphs 1-41 of the First Amended Complaint and denies FastVDO is entitled to any of the
`
`relief requested in its Prayer for Relief, to the extent such relief relates in any manner to Apple.
`
`RESPONSE TO PRAYER FOR RELIEF
`
`Apple denies that FastVDO is entitled to any of the relief sought in its prayer for relief
`
`against Apple on account of any action or omission of Apple. FastVDO’s prayer should,
`
`therefore, be denied in its entirety and with prejudice. Apple asks that judgment be entered for
`
`Apple and that this action be found to be an exceptional case under 35 U.S.C. § 285 entitling
`
`
`
`7
`
`
`
`

`
`Case 1:11-cv-00797-RGA Document 69 Filed 11/17/11 Page 8 of 13 PageID #: 366
`
`Apple to be awarded attorneys’ fees in defending against FastVDO’s First Amended Complaint,
`
`together with such other and further relief that the Court deems appropriate.
`
`AFFIRMATIVE DEFENSES
`
`By asserting the following defenses, Apple does not assume any burden of proof for any
`
`stated defense on which FastVDO bears the burden, including without limitation infringement.
`
`Pursuant to Federal Rule of Civil Procedure 8(c), Apple asserts the following additional defenses
`
`to FastVDO’s First Amended Complaint:
`
`FIRST AFFIRMATIVE DEFENSE
`(Noninfringement)
`
`Apple does not infringe and has not infringed, either directly or by inducing infringement
`
`of others, by contributing to the infringement of others, or at all, any claim of the ’081 Patent.
`
`SECOND AFFIRMATIVE DEFENSE
`(Invalidity)
`
`Each claim of the ’081 Patent is invalid for failure to meet one or more conditions and
`
`requirements for patentability specified in Title 35, United States Code, including without
`
`limitation, 35 U.S.C. §§ 101, 102, 103, and/or 112.
`
`THIRD AFFIRMATIVE DEFENSE
`(Willfulness - Failure to State a Claim)
`
`FastVDO has failed to plead its claim of willful infringement with sufficient specificity or
`
`factual support to place Apple on notice of the claims Plaintiff is asserting against it, such that
`
`Plaintiff has failed to state a claim upon which relief can be granted.
`
`FOURTH AFFIRMATIVE DEFENSE
`(Prosecution History Estoppel)
`
`On information and belief, FastVDO is barred, under the doctrine of Prosecution History
`
`Estoppel, from construing the claims of the’081 Patent in such a way as may cover any of Apple’s
`
`products or processes by reasons of amendments and/or statements made to the United States
`
`
`
`8
`
`
`
`

`
`Case 1:11-cv-00797-RGA Document 69 Filed 11/17/11 Page 9 of 13 PageID #: 367
`
`Patent and Trademark Office (“USPTO”) during the prosecution of the applications that led to the
`
`issuance of the respective patents.
`
`FIFTH AFFIRMATIVE DEFENSE
`(Limitation on Damages/Failure to Mark)
`
`On information and belief, FastVDO’s claims for damages for purported patent
`
`infringement are limited by 35 U.S.C. §§ 286 and/or 287. On information and belief, FastVDO’s
`
`purported claims for relief concerning the ’081 Patent are limited by failure to comply with the
`
`marking and notice requirements of 35 U.S.C. § 287(a).
`
`SIXTH AFFIRMATIVE DEFENSE
`(Laches/Waiver/Estoppel/Unclean Hands)
`
`On information and belief, FastVDO’s claims are barred, in whole or in part, by the
`
`equitable doctrines of laches, waiver, estoppel and/or unclean hands.
`
`SEVENTH AFFIRMATIVE DEFENSE
`(Limitation on Recovery of Costs)
`
`FastVDO is barred by 35 U.S.C. § 288 from recovering any costs associated with this
`
`action.
`
`EIGHTH AFFIRMATIVE DEFENSE
`(Violation of Reasonable and Non-Discriminatory Licensing Agreement)
`
`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
`
`10/Audio Video Coding standard and conditionally agreed to license its technology. Accordingly,
`
`FastVDO’s damages are limited by that agreement.
`
`NINTH AFFIRMATIVE DEFENSE
`(Intervening Rights)
`
`FastVDO’s claims of infringement of the ’081 Patent are bared in whole or in part by the
`
`doctrine of intervening rights, pursuant to 35 U.S.C. § 252.
`
`
`
`9
`
`
`
`

`
`Case 1:11-cv-00797-RGA Document 69 Filed 11/17/11 Page 10 of 13 PageID #: 368
`
`TENTH AFFIRMATIVE DEFENSE
`(Patent Misuse)
`
`On information and belief, the claims of the ’081 Patent are unenforceable due to patent
`
`misuse.
`
`ELEVENTH AFFIRMATIVE DEFENSE
`(Failure to State a Claim)
`
`FastVDO has failed to plead its claims with sufficient specificity or factual support to
`
`place Apple on notice of the claims Plaintiff is asserting against it, such that Plaintiff has failed to
`
`state a claim upon which relief can be granted.
`
`TWELFTH AFFIRMATIVE DEFENSE
`(No Right to Injunctive Relief)
`
`FastVDO’s claim for injunctive relief is barred because there exists an adequate remedy at
`
`law and FastVDO’s claims otherwise fail to meet the requirements for such relief.
`
`THIRTEENTH AFFIRMATIVE DEFENSE
`(Improper Joinder)
`
`Apple is not a party permitted to be joined to this action under Fed. R. Civ. P. 20, as no
`
`right to relief against Apple is alleged to or does arise out of the same transactions, occurrences or
`
`series of transactions or occurrences as any claim for relief alleged against any other defendant.
`
`ADDITIONAL AFFIRMATIVE DEFENSES
`
`
`
`Apple expressly reserves the right to assert additional affirmative and other defenses to
`
`which it is entitled, and further reserves the right to amend or supplement its affirmative defenses
`
`as the case progresses or as Apple obtains further information.
`
`
`
`
`
`COUNTERCLAIMS OF APPLE AGAINST FASTVDO
`
`Apple Inc. (“Apple”) hereby alleges the following Counterclaims against FastVDO, LLC
`
`(“FastVDO”). The following are counterclaims for a declaratory judgment of non-infringement
`
`
`
`10
`
`
`
`

`
`Case 1:11-cv-00797-RGA Document 69 Filed 11/17/11 Page 11 of 13 PageID #: 369
`
`and/or invalidity of the Asserted Patent U.S. Reissued Patent No. RE40,081 (“the ’081 Patent”).
`
`Apple, for its counterclaims herein, alleges as follows:
`
`PARTIES
`
`1.
`
`Counter-claimant Apple is a California corporation with its principal place of
`
`business at 1 Infinite Loop, Cupertino, California 95014.
`
`2.
`
`On information and belief, FastVDO is a Florida limited liability corporation with a
`
`place of business at 750 N. Atlantic Ave., Cocoa Beach, FL 32931.
`
`JURISDICTION AND VENUE
`These counterclaims seek declaratory and injunctive relief under the Declaratory
`
`3.
`
`Judgment Act, 28 U.S.C. §§ 2201 & 2202. The Court thus has subject matter jurisdiction of such
`
`claims pursuant to 28 U.S.C. § 1331 and 1338 as these counterclaims arise under the Patent Laws
`
`of the United States, set forth at 38 U.S.C. § 101 et seq.
`
`4.
`
`This Court has personal jurisdiction over Counter-defendant FastVDO because
`
`FastVDO submitted to the jurisdiction of this Court by filing its First Amended Complaint against
`
`Apple.
`
`5.
`
`Venue is proper in this judicial district because these claims are being brought as
`
`compulsory counterclaims pursuant to Fed. R. Civ. P. 13(a), and under 28 U.S.C. §§ 1391(b)
`
`and (c) and 1400(b) because the claims set forth herein involve federal questions of United States
`
`Patent Law.
`
`NATURE OF THE ACTION
`On October 31, 2011, FastVDO filed a First Amended Complaint against Apple,
`
`6.
`
`designated as Civil Action No. 11-cv-00797, alleging that by making, using, selling, offering to
`
`sell and/or importing within the United States devices and/or software, Apple has infringed,
`
`directly and/or indirectly, the ’081 Patent. An actual case or controversy between the parties
`
`
`
`11
`
`
`
`

`
`Case 1:11-cv-00797-RGA Document 69 Filed 11/17/11 Page 12 of 13 PageID #: 370
`
`exists because FastVDO has alleged and is alleging infringement of the ’081 Patent by Apple and
`
`because Apple denies those assertions.
`
`FIRST COUNTERCLAIM
`(Declaratory Judgment of Non-Infringement)
`
`7.
`
`An actual, continuing and justiciable controversy exists between Apple and
`
`FastVDO as to the non-infringement of the ’081 Patent, as evidenced by FastVDO’s First
`
`Amended Complaint and Apple’s Answer to that First Amended Complaint, as set forth above.
`
`8.
`
`Pursuant to the Federal Declaratory Judgment Act, 28 U.S.C. § 2201 et seq., Apple
`
`requests a judicial determination and declaration that Apple does not infringe and has not
`
`infringed, either directly or indirectly, any claim of the ’081 Patent.
`
`SECOND COUNTERCLAIM
`(Declaratory Judgment of Invalidity)
`
`9.
`
`An actual, continuing and justiciable controversy exists between Apple and
`
`FastVDO as to the invalidity of the ’081 Patent, as evidenced by FastVDO’s First Amended
`
`Complaint and Apple’s Answer to that First Amended Complaint, as set forth above.
`
`10.
`
`Pursuant to the Federal Declaratory Judgment Act, 28 U.S.C. § 2201 et seq., Apple
`
`requests a judicial determination and declaration the ’081 Patent is invalid for failure to meet one
`
`or more conditions and requirements for patentability specified in Title 35, United States Code,
`
`including without limitation, 35 U.S.C. §§ 101, 102, 103, and/or 112.
`
`DEMAND FOR A JURY TRIAL
`
`
`
`Apple hereby demands trial by jury for all issues so triable.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Apple prays for a declaration and judgment against Plaintiff and Counter-
`
`defendant FastVDO, LLC as follows:
`
`
`
`
`
`
`
`A.
`
`that FastVDO’s First Amended Complaint be dismissed with prejudice;
`
`
`
`12
`
`
`
`

`
`Case 1:11-cv-00797-RGA Document 69 Filed 11/17/11 Page 13 of 13 PageID #: 371
`
`B.
`
`that FastVDO be denied any and all relief it has requested in its First Amended
`
`Complaint;
`
`
`
`C.
`
`that the Court deny any preliminary or permanent injunctive relief in favor of
`
`FastVDO and against Apple;
`
`
`
`
`
`D.
`
`E.
`
`that FastVDO shall take nothing by way of its First Amended Complaint;
`
`that Apple has not infringed and is not infringing any valid claim of the ’081 Patent,
`
`directly or indirectly, literally or under the doctrine of equivalents;
`
`
`
`
`
`F.
`
`G.
`
`that each and all of the claims of the ’081 Patent are invalid;
`
`that the Court finds that this case is an exceptional case under 35 U.S.C. § 285, and
`
`that FastVDO be required to pay costs of suit that Apple has incurred, including attorneys’ fees and
`
`costs, pursuant to 35 U.S.C. § 285 and all other applicable statutes, rules and common law; and
`
`
`
`H.
`
`that Apple be granted such other and further relief as this Court deems just and
`
`equitable.
`
`Respectfully submitted this 17th day of November, 2011.
`
`
`
`
`
`Dated: November 17, 2011
`
`FISH & RICHARDSON P.C.
`
`
`
`/s/ Thomas L. Halkowski
`Thomas L. Halkowski (#4099)
`222 Delaware Avenue, 17th Floor
`P.O. Box 1114
`Wilmington, DE 19899-1114
`(302) 652-5070
`halkowski@fr.com
`
`Attorney for Defendant and
`Counter-claimant Apple Inc.
`
`By:
`
`
`
`
`13

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