Parallel Networks, LLC v. Adidas America, Inc. et al
Plaintiff's ANSWER to #301 Answer to Complaint, Counterclaim of Motorola, Inc. and Motorola Trademark Holdings, LLC 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 MOTOROLA, INC. AND MOTOROLA TRADEMARK HOLDINGS, LLC Plaintiff Parallel Networks, LLC ("Parallel Networks") hereby Answers the Counterclaims [Dkt. No. 301] of Defendant Motorola, Inc., and Motorola Trademark Holdings, LLC (collectively "Motorola"), by corresponding paragraph number as follows: ANSWER TO COUNTERCLAIMS The Parties 1. 2. Admitted. Admitted. Jurisdiction and Venue 3. 4. 5. 6. Admitted. Admitted. Admitted. Admitted. Existence of Justiciable Controversy 7. 8. Admitted. Admitted. 1 No. 6:10-cv-00491-LED Jury Trial Demanded
Admitted. Admitted. First Claim for Relief (Declaratory Judgment of Non-Infringement of the `111 Patent)
Parallel Networks incorporates by reference its statements in and responses to the
preceding paragraphs 1-10 as if fully set forth herein. 12. Denied. Second Claim for Relief (Declaratory Judgment of Invalidity of the `111 Patent) 13. Parallel Networks incorporates by reference its statements in and responses to the
preceding paragraphs 1-10 as if fully set forth herein. 14. Denied. Demand for Jury Trial Motorola's Demand for Jury Trial is an averment to which no responsive pleading is required. Prayer for Relief Parallel Networks denies that Motorola is entitled to any relief, including that requested in its Prayer for Relief.
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 Irving, Texas 75039 214-785-6014 (phone) email@example.com 2
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: (312) 803-0437 Email: firstname.lastname@example.org email@example.com 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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