312. Denied.13. Denied.14. Denied.
DEMAND FOR JURY TRIAL
To the extent a response is required, Amazon admits that Plaintiff’s Complaint contains ademand for a jury trial.
Except as specifically admitted, Amazon denies each and every allegation contained in paragraphs 1–14 of the Complaint and denies that Plaintiff is entitled to any of the relief requested in its Prayer for Relief.
Pursuant to Federal Rule of Civil Procedure 8(c), and without conceding that any of thefollowing necessarily must be pled as an affirmative defense or that Amazon necessarily bearsthe burden of proof or persuasion for any of the following, Amazon asserts the followingadditional defenses to Plaintiff’s Complaint.
FIRST ADDITIONAL DEFENSE(Noninfringement)
15. Amazon does not infringe and has not infringed (either directly, contributorily, or by inducement) any claim of the ’783 patent, either literally or under the doctrine of equivalents.
SECOND ADDITIONAL DEFENSE(Invalidity)
16. One or more asserted claims of the ’783 patent are invalid for failure to complywith one or more provisions of Title 35 of the United States Code, including, without limitation,one or more of §§ 101, 102, 103, or 112.
Case 1:13-cv-11097-FDS Document 15 Filed 06/14/13 Page 3 of 7