COUNTERCLAIM DEFENDANT APPLE INC.’S AMENDEDANSWER, DEFENSES AND COUNTERCLAIMS IN REPLYTO SAMSUNG’S COUNTERCLAIMSCase No. 11-cv-01846 (LHK)
SAMSUNG ELECTRONICS CO., LTD., aKorean business entity, SAMSUNGELECTRONICS AMERICA, INC., a NewYork corporation, and SAMSUNGTELECOMMUNICATIONS AMERICA,LLC, a Delaware limited liability company, aCalifornia corporation,Counterclaim-Plaintiff,v.APPLE INC., a California corporation,Counterclaim-Defendants.
This is Apple Inc.’s (“Apple”) amended responsive pleading under Fed. R.Civ. P. 12, and contains Apple’s defenses to the counterclaims asserted by defendants andcounterclaim-plaintiffs Samsung Electronics Co., Ltd., Samsung Electronics America,Inc., and Samsung Telecommunications America, LLC (collectively, “Samsung”), aswell as Apple’s Counterclaims In Reply to Samsung’s Counterclaims.2.
Apple responds to the allegations contained in the numbered paragraphs of Samsung’s Counterclaims below, but first provides this overview of its response.3.
Apple is a pioneer in mobile phone and tablet computer design andtechnology. Apple has designed its mobile phones and tablet computers with distinctivefeatures that make them immediately recognizable as iPhones and iPads. Apple hascoupled these distinguishing design details with a highly advanced interface that makesthe iPhone and iPad user experience simple, intuitive, and efficient. Apple spendsbillions of dollars annually on research and development, and has applied for andreceived numerous design and utility patents to protect its innovations from copying.4.
Samsung has illicitly copied Apple’s distinctive design features andinnovative technologies instead of pursuing its own independent and costly product
Case5:11-cv-01846-LHK Document381 Filed11/08/11 Page2 of 87