Parallel Networks, LLC v. Adidas America, Inc. et al
Filing
410
Plaintiff's ANSWER to #328 Answer to Complaint, Counterclaim of American Suzuki Motor Corporation 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 AMERICAN SUZUKI MOTOR CORPORATION Plaintiff Parallel Networks, LLC ("Parallel Networks") hereby Answers the Counterclaims [Dkt. No. 328] of Defendant American Suzuki Motor Corporation ("Suzuki"), by corresponding paragraph number as follows: ANSWER TO COUNTERCLAIMS PARTIES 1. 2. Admitted. Admitted. JURISDICTION AND VENUE 3. Admits that Suzuki filed an action for declaratory relief, but denies that Suzuki is No. 6:10-cv-00491-LED Jury Trial Demanded
entitled to any relief. 4. 5. 6. Admitted. Admitted. Admits that Suzuki denies Parallel Networks' claim of infringement of the `111
patent, but denies that Suzuki does not infringe. 7. Admitted. 1
COUNTERCLAIM ONE (Declaratory Judgment of Noninfringement of the `111 Patent) 8. Parallel Networks incorporates by reference its statements in and responses to the
preceding paragraphs 1-7 as if fully set forth herein. 9. 10. Admitted. Admits that Parallel Networks makes such a statement in paragraph 83 of the
Complaint, but denies that the quotation is the complete assertion in paragraph 83. 11. Admits that Suzuki denies Parallel Networks' claims of infringement and believes
that the Complaint has been filed without good cause, but denies such assertions. All remaining allegations in the paragraph are denied. 12. 13. Admitted. Denied. COUNTERCLAIM TWO (Declaratory Judgment of Invalidity of the '111 patent) 14. Parallel Networks incorporates by reference its statements in and responses to the
preceding paragraphs 1-13 as if fully set forth herein. 15. Admits that Suzuki denies that the '111 patent is valid and asserts that the '111
patent is invalid for failure to comply with the requirements of 35 U.S.C. § 101 et seq., but denies such assertions. All remaining allegations in the paragraph are denied. 16. 17. Admitted. Denied.
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PRAYER Parallel Networks denies that Suzuki is entitled to any relief, including that requested in its Prayer for Relief. DEMAND FOR A JURY TRIAL Suzuki's Demand for a Jury Trial 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 Irving, Texas 75039 214-785-6014 (phone) craig@tadlocklawfirm.com 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: gbosy@bosybennett.com dbennett@bosybennett.com ATTORNEYS FOR PLAINTIFF PARALLEL NETWORKS, LLC
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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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