Parallel Networks, LLC v. Adidas America, Inc. et al

Filing 395

Plaintiff's ANSWER to #261 Answer to Complaint, Counterclaim of HSN Interactive LLC's and HSN LP's by Parallel Networks, LLC.(Tadlock, Charles)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION Parallel Networks, LLC, Plaintiff, v. Adidas America, Inc. et al. Defendants PLAINTIFF'S ANSWER TO THE COUNTERCLAIMS OF HSN INTERACTIVE LLC'S AND HSN LP'S Plaintiff Parallel Networks, LLC ("Parallel Networks") hereby Answers the Counterclaims [Dkt. No. 261] of Defendant HSN Interactive LLC ("HSNI") and HSN LP (collectively "HSN"), by corresponding paragraph number as follows: ANSWER TO COUNTERCLAIMS THE PARTIES 1. 2. 3. Admitted. Admitted. Admitted. JURISDICTION AND VENUE 4. 5. 6. 7. 8. Admitted. Admitted. Admitted. Admitted. Admitted. COUNT I 1 No. 6:10-cv-00491-LED Jury Trial Demanded

DECLARATORY JUDGMENT OF NONINFRINGEMENT OF THE `111 PATENT 9. Parallel Networks incorporates by reference its statements in and responses to the

preceding paragraphs 1-8 as if fully set forth herein. 10. 11. 12. 13. Denied. Denied. Denied. Denied.

COUNT II DECLARATORY JUDGMENT OF INVALIDITY OF THE `111 PATENT 14. Parallel Networks incorporates by reference its statements in and responses to the

preceding paragraphs 1-8 as if fully set forth herein. 15. 16. 17. Denied. Denied. Denied. PRAYER FOR RELIEF Parallel Networks denies that HSN is entitled to any relief, including that requested in its Prayer for Relief. JURY TRIAL DEMAND HSN's Jury Trial Demand is an averment to which no responsive pleading is required.

Dated: December 16, 2010

Respectfully submitted, By: /s/ Charles Craig Tadlock Charles Craig Tadlock Texas State Bar No. 00791766 TADLOCK LAW FIRM 400 E. Royal Lane, Suite 290 2

Irving, Texas 75039 214-785-6014 (phone) [e-mail] and 315 N. Broadway, Suite 307 Tyler, Texas 75702 903-283-2758 (phone) George S. Bosy (pro hac vice) David R. Bennett (pro hac vice) Bosy & Bennett 300 N. La Salle St. 49th Floor Chicago, IL 60654 Telephone: [phone] Email: [e-mail] [e-mail] ATTORNEYS FOR PLAINTIFF PARALLEL NETWORKS, LLC

CERTIFICATE OF SERVICE I hereby certify that counsel of record who are deemed to have consented to electronic service are being served this 16th day of December, 2010, with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3). Any other counsel of record will be served by electronic mail, facsimile transmission and/or first class mail on this same date. /s/ Charles Craig Tadlock One of the Attorneys for Parallel Networks, LLC

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