`Case 1:11—cv-00797-RGA Document 76
`Filed 12/08/11 Page 1 of 3 Page|D #: 401
`
`UNITED STATES DISTRICT COURT
`
`DISTRICT OF DELAWARE
`
`FastVDO LLC,
`
`V.
`
`Apple Inc., et al.,
`
`Plaintiff,
`
`Defendants.
`
`C.A. No. 11-797-RGA
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF FASTVDO LLC’S ANSWER TO DEFENDANT CASIO AMERICA
`INC.’S COUNTERCLAIMS
`
`Plaintiff FastVDO, LLC (“FastVDO”), by and through its undersigned attorneys,
`
`answers the counterclaims of Defendant Casio America, Inc. (“Casio”) by corresponding
`
`paragraph number as follows:
`
`COUNTERCLAIM
`
`1 .
`
`2.
`
`3.
`
`“‘08l Patent”).
`
`4.
`
`5.
`
`6.
`
`Admitted.
`
`Admitted.
`
`FastVDO admits that it is the owner of U.S. Patent No. RE 40,081 (the
`
`Admitted.
`
`FastVDO admits that Venue is proper in this district.
`
`FastVDO admits that Casio purports to state a claim arising under the
`
`patent laws of the United States, Title 35 of the United States Code, and the Federal
`
`Declaratory Judgment Act, and that this Court has jurisdiction over the subject matter of
`
`this action. FastVDO denies the merits of Casio’s counterclaims and that Casio is
`
`
`
`Case 1:11-cv-00797-RGA Document 76 Filed 12/08/11 Page 2 of 3 PageID #: 402
`Case 1:11—cv-00797-RGA Document 76
`Filed 12/08/11 Page 2 of 3 Page|D #: 402
`
`entitled to any of its requested relief. FastVDO denies the remaining allegations in this
`
`paragraph.
`
`7.
`
`FastVDO admits that there exists an actual and justiciable controversy
`
`between FastVDO and Casio regarding the validity of the ‘081 Patent and Casio’s
`
`infringement of the ‘O81 Patent. FastVDO denies the remaining allegations in this
`
`paragraph.
`
`8.
`
`9.
`
`Denied.
`
`Denied.
`
`10.
`
`Denied.
`
`DEMAND FOR JURY TRIAL
`
`FastVDO demands a trial by jury on all issues so triable.
`
`PRAYER F OR REl..lF.l<‘
`
`WHEREFORE, FastVDO prays for the following relief with regard to Casio’s
`
`counterclaims:
`
`A.
`
`B.
`
`A dismissal with prejudice of Casio’s counterclaims;
`
`An adjudication that Casio is not entitled to any relief on its counterclaims,
`
`including, without limitation, any fine or damages;
`
`C.
`
`Costs and further relief to which FastVDO is entitled, and which the Court
`
`deems just and equitable.
`
`
`
`Case 1:11-cv-00797-RGA Document 76 Filed 12/08/11 Page 3 of 3 PageID #: 403
`Case 1:11—cv-00797-RGA Document 76
`Filed 12/08/11 Page 3 of 3 Page|D #: 403
`
`Date: December 8, 2011
`
`FARNAN LLP
`
`Respectfully submitted,
`
`/s/ Brian E. Farnan
`
`Joseph J. Farnan, Jr. (Bar No. 100245)
`Brian E. Farnan (Bar No. 4089)
`919 North Market Street, 12th Floor
`
`Wilmington, DE 19801
`(302) 777-0300
`bfarnan@farnanlaw.com
`
`» Alexander C.D. Giza (admitted pro hac vice)
`Marc A. Fenster (admitted pro hac vice)
`Kevin P. Burke (admitted pro hac vice)
`RUSS, AUGUST & KABAT
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, CA 90025-1031
`(310) 826-7474
`agiza@raklaw.com
`mfenster@raklaw.com
`kburke@raklaw.com
`
`Attorneys for PlairitiflFastVDO, LLC
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