Case 1:11-cv-00797-RGA Document 87 Filed 12/19/11 Page 1 of 13 PageID #: 454
`Case 1:11-cv—00797-RGA Document 87
`Filed 12/19/11 Page 1 of 13 Page|D #: 454
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF DELAWARE
`
`FASTVDO LLC,
`
`I
`
`v.
`APPLE INC, et al.,
`
`Plaintiff,
`
`Defendants.
`
`i
`i C.A. No. 11-797-RGA
`i
`i
`
`ANSWER OF HEWLETT-PACKARD COMPANY TO
`
`FASTVDO LLC’S FIRST AMENDED COMPLAINT
`
`Defendant Hewlett-Packard Company (“HP”), by and through its attorneys, responds to
`
`the averments made in the numbered paragraphs of the First Amended Complaint filed by
`
`Plaintiff FastVDO LLC (“FastVDO”) on October 31, 2011, as follows.
`
`PARTIES‘
`
`1.
`
`The allegations of Paragraph 1 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 1, and therefore, denies
`
`the same.
`
`2.
`
`The allegations of Paragraph 2 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 2, and therefore, denies
`
`the same.
`
`3.
`
`The allegations of Paragraph 3 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`‘
`
`The headings in the First Amended Complaint are reproduced herein for the convenience of the reader. HP
`does not admit, and instead denies, any allegations contained in or implied by the headings.
`
`
`Case 1:11-cv—00797-RGA Document 87
`Filed 12/19/11 Page 1 of 13 Page|D #: 454
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF DELAWARE
`
`FASTVDO LLC,
`
`I
`
`v.
`APPLE INC, et al.,
`
`Plaintiff,
`
`Defendants.
`
`i
`i C.A. No. 11-797-RGA
`i
`i
`
`ANSWER OF HEWLETT-PACKARD COMPANY TO
`
`FASTVDO LLC’S FIRST AMENDED COMPLAINT
`
`Defendant Hewlett-Packard Company (“HP”), by and through its attorneys, responds to
`
`the averments made in the numbered paragraphs of the First Amended Complaint filed by
`
`Plaintiff FastVDO LLC (“FastVDO”) on October 31, 2011, as follows.
`
`PARTIES‘
`
`1.
`
`The allegations of Paragraph 1 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 1, and therefore, denies
`
`the same.
`
`2.
`
`The allegations of Paragraph 2 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 2, and therefore, denies
`
`the same.
`
`3.
`
`The allegations of Paragraph 3 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`‘
`
`The headings in the First Amended Complaint are reproduced herein for the convenience of the reader. HP
`does not admit, and instead denies, any allegations contained in or implied by the headings.
`
`
`
`Case 1:11-cv-00797-RGA Document 87 Filed 12/19/11 Page 2 of 13 PageID #: 455
`Case 1:11—cv—00797-RGA Document 87
`Filed 12/19/11 Page 2 of 13 Page|D #: 455
`
`sufficient to form a belief about the truth of the allegations in Paragraph 3, and therefore, denies
`
`the same.
`
`4.
`
`The allegations of Paragraph 4 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 4, and therefore, denies
`
`the same.
`
`5.
`
`The allegations of Paragraph 5 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 5, and therefore, denies
`
`the same.
`
`6.
`
`The allegations of Paragraph 6 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 6, and therefore, denies
`
`the same.
`
`7.
`
`The allegations of Paragraph 7 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 7, and therefore, denies
`
`the same.
`
`8.
`
`The allegations of Paragraph 8 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 8, and therefore, denies
`
`the same.
`
`
`
`Case 1:11-cv-00797-RGA Document 87 Filed 12/19/11 Page 3 of 13 PageID #: 456
`Case 1:11—cv—00797-RGA Document 87
`Filed 12/19/11 Page 3 of 13 Page|D #: 456
`
`9.
`
`HP admits that Hewlett-Packard Company is a corporation organized and existing
`
`under the laws of the state of Delaware, with its principal place of business at 3000 Hanover
`
`Street, Palo Alto, CA 943 04.
`
`10.
`
`The allegations of Paragraph 10 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 10, and therefore, denies
`
`the same.
`
`1 1.
`
`The allegations of Paragraph 11 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 11, and therefore, denies
`
`the same.
`
`12.
`
`The allegations of Paragraph 12 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 12, and therefore, denies
`
`the same.
`
`13.
`
`The allegations of Paragraph 13 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 13, and therefore, denies
`
`the same.
`
`14.
`
`The allegations of Paragraph 14 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 14, and therefore, denies
`
`the same.
`
`
`
`Case 1:11-cv-00797-RGA Document 87 Filed 12/19/11 Page 4 of 13 PageID #: 457
`Case 1:11—cv—00797-RGA Document 87
`Filed 12/19/11 Page 4 of 13 Page|D #: 457
`
`15.
`
`The allegations of Paragraph 15 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 15, and therefore, denies
`
`the same.
`
`16.
`
`The allegations of Paragraph 16 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 16, and therefore, denies
`
`the same.
`
`17.
`
`The allegations of Paragraph 17 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 17, and therefore, denies
`
`the same.
`
`18.
`
`The allegations of Paragraph 18 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations ir1 Paragraph 18, and therefore, denies
`
`the same.
`
`19.
`
`The allegations of Paragraph 19 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 19, and therefore, denies
`
`the same.
`
`20.
`
`The allegations of Paragraph 20 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`
`
`Case 1:11-cv-00797-RGA Document 87 Filed 12/19/11 Page 5 of 13 PageID #: 458
`Case 1:11—cv—00797-RGA Document 87
`Filed 12/19/11 Page 5 of 13 Page|D #: 458
`
`sufficient to form a belief about the truth of the allegations in Paragraph 20, and therefore, denies
`
`the same.
`
`JURISDICTION AND VENUE
`
`21.
`
`HP admits that Plaintiffs First Amended Complaint purports to be an action for
`
`patent infiingement arising under the patent laws of the United States, Title 35 of the United
`
`States Code. HP further admits that this Court has jurisdiction under 28 U.S.C. §§ 1331 and
`
`1338(a).
`
`22.
`
`HP admits that it is a corporation organized and existing under the laws of the
`
`state of Delaware. HP does not contest jurisdiction in this Court. HP denies the remaining
`
`allegations of Paragraph 22 as they relate to HP. To the extent the remaining allegations of
`
`Paragraph 22 are not directed to HP, no response by HP is required; to the extent any response is
`
`required, HP lacks knowledge or information sufficient to form a belief about the truth of the
`
`allegations in Paragraph 22, and therefore, denies the same.
`
`23.
`
`The allegations of Paragraph 23 state a legal conclusion to which no response is
`
`required. To the extent any response is required, HP denies that venue is proper in this Court as
`
`to HP. HP denies that it has committed any act of patent infringement in this District and denies
`
`the remaining allegations of Paragraph 23 as they relate to HP. To the extent the remaining
`
`allegations of Paragraph 23 are not directed to HP, no response by HP is required; to the extent
`
`any response is required, HP lacks knowledge or information sufficient to form a belief about the
`
`truth of the allegations in Paragraph 23, and therefore, denies the same.
`
`
`
`Case 1:11-cv-00797-RGA Document 87 Filed 12/19/11 Page 6 of 13 PageID #: 459
`Case 1:11—cv—00797-RGA Document 87
`Filed 12/19/11 Page 6 of 13 Page|D #: 459
`
`COUNT I
`
`flnfringment of U.S. Patent No. RE 40,081)
`
`24.
`
`HP admits that U.S. Patent No. RE 40,081 (“the ’081 patent”) is entitled “Fast
`
`Signal Transforms With Lifting Steps.” HP further admits that a copy of the ’081 patent is
`
`attached as Exhibit A to the First Amended Complaint. HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the remaining allegations in Paragraph 24, and
`
`therefore, denies the same.
`
`25.
`
`The allegations of Paragraph 25 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 25, and therefore, denies
`
`the same.
`
`26.
`
`The allegations of Paragraph 26 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 26, and therefore, denies
`
`the same.
`
`27.
`
`The allegations of Paragraph 27 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 27, and therefore, denies
`
`the same.
`
`28.
`
`The allegations of Paragraph 28 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 28, and therefore, denies
`
`the same.
`
`
`
`Case 1:11-cv-00797-RGA Document 87 Filed 12/19/11 Page 7 of 13 PageID #: 460
`Case 1:11—cv—00797-RGA Document 87
`Filed 12/19/11 Page 7 of 13 Page|D #: 460
`
`29.
`
`The allegations of Paragraph 29 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 29, and therefore, denies
`
`the same.
`
`30.
`
`The allegations of Paragraph 30 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 30, and therefore, denies
`
`the same.
`
`31.
`
`The allegations of Paragraph 31 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 31, and therefore, denies
`
`the same.
`
`32.
`
`HP denies the allegations in Paragraph 32.
`
`33.
`
`The allegations of Paragraph 33 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or infonnation
`
`sufficient to form a belief about the truth of the allegations in Paragraph 33, and therefore, denies
`
`the same.
`
`34.
`
`The allegations of Paragraph 34 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or infonnation
`
`sufficient to form a belief about the truth of the allegations in Paragraph 34, and therefore, denies
`
`the same.
`
`35.
`
`The allegations of Paragraph 35 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`
`
`Case 1:11-cv-00797-RGA Document 87 Filed 12/19/11 Page 8 of 13 PageID #: 461
`Case 1:11—cv—00797-RGA Document 87
`Filed 12/19/11 Page 8 of 13 Page|D #: 461
`
`sufficient to form a belief about the truth of the allegations in Paragraph 35, and therefore, denies
`
`the same.
`
`36.
`
`The allegations of Paragraph 36 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or infonnation
`
`sufficient to form a belief about the truth of the allegations in Paragraph 36, and therefore, denies
`
`the same.
`
`37.
`
`The allegations of Paragraph 37 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or infonnation
`
`sufficient to form a belief about the truth of the allegations in Paragraph 37, and therefore, denies
`
`the same.
`
`38.
`
`The allegations of Paragraph 38 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or infonnation
`
`sufficient to form a belief about the truth of the allegations in Paragraph 38, and therefore, denies
`
`the same.
`
`39.
`
`The allegations of Paragraph 39 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 39, and therefore, denies
`
`the same.
`
`40.
`
`The allegations of Paragraph 40 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 40, and therefore, denies
`
`the same.
`
`
`
`Case 1:11-cv-00797-RGA Document 87 Filed 12/19/11 Page 9 of 13 PageID #: 462
`Case 1:11—cv—00797-RGA Document 87
`Filed 12/19/11 Page 9 of 13 Page|D #: 462
`
`41.
`
`The allegations of Paragraph 41 are not directed to HP, and therefore, no response
`
`by HP is required. To the extent any response is required, HP lacks knowledge or information
`
`sufficient to form a belief about the truth of the allegations in Paragraph 41, and therefore, denies
`
`the same.
`
`AFFIRMATIVE DEFENSES
`
`As separate defenses to the averments contained in Paragraph 1-41 of the First Amended
`
`Complaint, HP avers as follows:
`
`First Affirmative Defense
`
`(Failure to State a Claim)
`
`1.
`
`Plaintiff has failed to state a claim upon which any relief may be granted against
`
`Second Affirmative Defense
`
`(Patent Non-Infringement)
`
`2.
`
`HP has not infiinged and is not infringing, directly or indirectly, any valid and
`
`enforceable claim of the ’081 Patent, either literally or under the doctrine of equivalents.
`
`Third Affirmative Defense
`
`(Patent Invalidity)
`
`3.
`
`The ’081 Patent is invalid for failure to meet the conditions of patentability of 35
`
`U.S.C. § 101 et seq., including without limitation, §§ 101, 102, 103, 112, 121, and/or 251.
`
`
`
`Case 1:11-cv-00797-RGA Document 87 Filed 12/19/11 Page 10 of 13 PageID #: 463
`Case 1:11—cv—00797-RGA Document 87
`Filed 12/19/11 Page 10 of 13 Page|D #: 463
`
`Eighth Affirmative Defense
`
`(Express or Implied License)
`
`8.
`
`HP has an express or implied license to practice some or all of the claims in the
`
`’081 patent.
`
`Ninth Affirmative Defense
`
`(Absolute and Equitable Intervening Rights)
`
`9.
`
`Plaintiffs claims and requested relief are barred in whole or in part by 35 U.S.C.
`
`§ 252 to the extent Plaintiff alleges infringement of the ’081 patent by HP products
`
`manufactured, used, sold, offered for sale, or imported into the United States, and/or for which
`
`substantial preparations therefor were undertaken prior to the date the patent issued or reissued.
`
`Tenth Affirmative Defense
`
`(Patent Unenforceability)
`
`10.
`
`The Joint Video Team (“JVT”) is the standardization body for the ITU H.264
`
`Standard and the ISO/IEC 14496-10 (MPEG-4 AVC) Standard (collectively, the “H.264/MPEG-
`
`4 AVC Standard”) for video compression.
`
`11.
`
`The H.264 Standard and MPEG-4 AVC Standard are jointly maintained so that
`
`they have identical technical content.
`
`12.
`
`The H.264/MPEG-4 AVC Standard is a standard for video recording,
`
`compression and distribution of high definition (“HD”) video.
`
`13.
`
`The consumer electronics industry has relied and continues to rely on the JVT to
`
`develop and maintain a video compression standard for world-wide distribution of HD video.
`
`14.
`
`The JVT is operated and continues to operate through a committee of video
`
`coding industry representatives. In developing the H.264/MPEG-4 AVC Standard, proposals for
`
`11
`
`
`
`Case 1:11-cv-00797-RGA Document 87 Filed 12/19/11 Page 11 of 13 PageID #: 464
`Case 1:11—cv—00797-RGA Document 87
`Filed 12/19/11 Page 11 of 13 Page|D #: 464
`
`inclusion in the standard were made at JVT meetings primarily by its members. In the intervals
`
`between the meetings, members invested time and resources evaluating these proposals for
`
`suitability. Over a series of meetings, input from industry participants was considered.
`
`Eventually, a consensus emerged on the specific set of features to be included in the standard.
`
`15.
`
`The JVT has rules and procedures that are designed to prevent its participants
`
`from using the JVT for anticompetitive or illegal purposes. One specific kind of anticompetitive
`
`effect that the JVT guards against is the unintended inclusion of patented elements in the
`
`H.264/MPEG-4 AVC Standard. The JVT requires that each proposal include a disclosure to
`
`indicate whether the proposal includes any technology from granted, pending or plarmed patents.
`
`Although the JVT does not prohibit the inclusion of patented technology, the JVT’s policy sets
`
`forth a preference for a baseline profile that is royalty-free.
`
`16.
`
`FastVDO submitted several proposals to the JVT during the development of the
`
`H.264/MPEG-4 AVC Standard.
`
`17.
`
`These rules, among other things, required submitters, including FastVDO, to
`
`disclose to the JVT any patents, patent applications or intentions to file patents that might bear
`
`upon proposals being considered by the JVT.
`
`18.
`
`On information and belief, FastVDO agreed, both explicitly and implicitly, that it
`
`would abide by the rules governing the JVT submissions as a result of its participation in the
`
`JVT.
`
`19.
`
`By participating in the JVT, FastVDO knew or should have known that
`
`companies would be reasonably induced to rely upon FastVDO’s promises and representations
`
`that it would disclose any patents, patent applications, or intentions to file patents that may bear
`
`upon proposals being considered by the JVT.
`
`12
`
`
`
`Case 1:11-cv-00797-RGA Document 87 Filed 12/19/11 Page 12 of 13 PageID #: 465
`Case 1:11—cv—00797-RGA Document 87
`Filed 12/19/11 Page 12 of 13 Page|D #: 465
`
`20.
`
`The final draft of the first version of the H.264/MPEG-4 AVC Standard was
`
`completed in May 2003.
`
`21.
`
`In May 2003, FastVDO submitted to the JVT a patent statement and licensing
`
`declaration for U.S. Patent No. 6,421,464 (“the ’464 patent”) stating that it will provide a license
`
`for the ’464 patent on reasonable and non-discriminatory (“RAND”) terms.
`
`22.
`
`By being a participant in the JVT, FastVDO gained insight into the industry’s
`
`efforts to develop an advanced video compression standard.
`
`23.
`
`Two months after the completion of the final draft of the first version of the
`
`H.264/MPEG-4 AVC Standard, FastVDO filed a reissue application for the ’464 patent in order
`
`to broaden the claims to cover the Standard. As a result, the ’08l patent (reissue of the ’464
`
`patent) was issued.
`
`24.
`
`As a result of Plaintiffs interactions with one or more standards setting
`
`organizations, including but not limited to the JVT, and parties related to the H.264/MPEG-4
`
`AVC Standard, the ’08l patent is unenforceable due to waiver and/or equitable estoppel.
`
`Eleventh Affirmative Defense
`
`(Misjoinder)
`
`25.
`
`Plaintiffs claims are barred, in whole or in part, because some or all of the parties
`
`have been improperly joined in this action.
`
`RESPONSE TO FASTVDO’S PRAYER FOR RELIEF
`
`HP denies that Plaintiff is entitled to any relief whatsoever against HP in this action,
`
`either as prayed for in the First Amended Complaint or otherwise. Instead, HP requests that this
`
`Court enter an Order:
`
`(a)
`
`DISMISSING FastVDO’s claims against HP WITH PREJUDICE;
`
`13
`
`
`
`Case 1:11-cv-00797-RGA Document 87 Filed 12/19/11 Page 13 of 13 PageID #: 466
`Case 1:11—cv—00797-RGA Document 87
`Filed 12/19/11 Page 13 of 13 Page|D #: 466
`
`(b)
`
`Awarding HP its costs and expenses incurred by this case, including an attorney
`
`fees award under 35 U.S.C. § 285.
`
`(c)
`
`Awarding HP such further relief as this Court deems just and proper.
`
`DEMAND FOR JURY TRIAL
`
`HP respectfiilly requests a trial by jury on all issues so triable in accordance with Fed. R.
`
`Civ. P. 38.
`
`Dated: December 19, 2011
`
`MORGAN, LEWIS & BOCKIUS LLP
`
`/s/ Ram}; E. Hanna
`Colrn F. Connolly (#3 15 1)
`Ramy E. Harma (#5494)
`cconnolly@morganlewis.com
`rharma@morganlewis.com
`The Nemours Building
`1007 North Orange Street, Suite 501
`Wilmington, DE 19801
`302.574.3000
`
`Mark W. Taylor
`mark.taylor@morganlewis.com
`11 11 Pennsylvania Ave., NW
`Washington, DC 20009
`202.739.3000
`
`Counselfor Defendant Hewlett-Packard
`Company
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