Case No. 12-CV-00630-LHK SAMSUNG DEFENDANTS’ ANSWER AFFIRMATIVE DEFENSES AND COUNTERCLAIMS
wide range of products, including consumer electronics, computer components, and mobile andentertainment products.7.The Samsung Defendants admit that SEA is a New York corporation, was formedin 1978, and is a subsidiary of SEC. The Samsung Defendants admit that SEA’s principal officesare located at 85 Challenger Road, Ridgefield Park, NJ, 07660. The Samsung Defendants admitthat SEA offers a full range of award-winning consumer electronics and IT products including, butnot limited to, televisions, Blu-ray disc players, digital cameras and camcorders, certain memorystorage devices, portable audio devices, printers and monitors.The Samsung Defendants admitthat STA, Samsung Electronics Canada, andSamsung Electronics Mexico S.A. de C.V. areaffiliates of SEA. The Samsung Defendants denythe remaining allegations of paragraph 7of theComplaint.8.The Samsung Defendants admit that STA was formed in 1996 and is a subsidiaryof SEC. The Samsung Defendants admit that STA is a Delaware limited liability company withits principal place of business at 1301 East Lookout Drive, Richardson, Texas 75082. TheSamsung Defendants admit that STA researches, develops, markets, sells and offers for sale avariety of personal and business communications products throughout North America, includinghandheld wireless phones, wireless communications infrastructure systems, fiber optics andenterprise communication systems.
9.The Samsung Defendants admit that the Complaint purports to allege claims over which this Court has subject matter jurisdiction under 28 U.S.C. § 1331 and 28 U.S.C. § 1338(a).Except as expressly admitted, the Samsung Defendants deny the remaining allegations of paragraph 9 of the Complaint.10.The Samsung Defendants will not challenge personal jurisdiction over them by thisCourt for purposes of this action. Except as expressly admitted, the Samsung Defendants deny theremaining allegations of paragraph 10 of the Complaint.
Case5:12-cv-00630-LHK Document107 Filed04/18/12 Page3 of 31