Case 1:14-cv-00130-GMS Document 170 Filed 06/30/15 Page 1 of 72 PageID #: 7958
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 14-130-GMS
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`JURY TRIAL DEMANDED
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`))))))))))
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`ADIDAS AG,
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`Plaintiff,
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`v.
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`UNDER ARMOUR, INC. and
`MAPMYFITNESS, INC.,
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`Defendants.
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`MAPMYFITNESS, INC.’S ANSWER, DEFENSES, AND COUNTERCLAIMS TO
`PLAINTIFF’S SECOND AMENDED COMPLAINT FOR PATENT INFRINGEMENT
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`MapMyFitness, Inc., (“MMF”) through its undersigned counsel, hereby responds to the
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`Second Amended Complaint for Patent Infringement and Demand for Jury Trial (“the
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`Complaint”) filed by adidas AG (“adidas” or “Plaintiff”) as follows:
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`I. ANSWER
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`GENERAL DENIAL
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`Unless expressly admitted below, MMF denies each and every allegation set forth in the
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`Complaint. MMF further specifically responds to the allegations asserted by adidas in the
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`paragraphs below, which correspond to the paragraph numbers of the Complaint:
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`NATURE OF ACTION
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`1.
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`MMF admits that Plaintiff has brought an action for patent infringement under 35
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`U.S.C. § 1, et seq., but denies any wrongdoing or liability for the reasons stated herein. MMF is
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`without knowledge or information sufficient to form a belief as to the truth of the allegation that
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`adidas owns the patents it has asserted, and on that basis, denies the allegation.
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`Patent Owner adidas AG
`Exhibit 2021 - Page 1 of 152
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`

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`Case 1:14-cv-00130-GMS Document 170 Filed 06/30/15 Page 2 of 72 PageID #: 7959
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`THE PARTIES
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`2.
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`MMF admits that the Complaint alleges that adidas AG is a corporation organized
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`under the laws of the Federal Republic of Germany, with its principal place of business at Adi-
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`Dassler-Strasse 1, 91074 Herzogenaurach, Germany. MMF is without knowledge or information
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`sufficient to form a belief as to the truth of the allegation, and on that basis, denies the allegation.
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`3.
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`MMF admits that the Complaint alleges that adidas America, Inc. is a corporation
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`organized under the laws of Delaware, with its principal place of business at 5055 North Greeley
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`Avenue, Portland, OR, 97217-3524. MMF is without knowledge or information sufficient to
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`form a belief as to the truth of the allegation, and on that basis, denies the allegation.
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`4.
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`5.
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`MMF admits the facts alleged in Paragraph 4 of the Complaint.
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`MMF admits that it is a corporation organized under the laws of Delaware and a
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`subsidiary of Under Armour, but notes that its principal place of business is located at 619 West
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`5th Street, Austin, TX.
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`JURISDICTION AND VENUE
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`6.
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`MMF admits that the Complaint purports to be an action that arises under the
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`patent laws of the United States, Title 35 of the United States Code, and that this court has
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`subject matter jurisdiction over this matter pursuant to 28 U.S.C. §§ 1331 and 1338(a), but
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`denies any wrongdoing or liability for the reasons stated herein.
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`7.
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`8.
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`MMF admits the facts alleged in Paragraph 7 of the Complaint.
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`MMF is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations contained in Paragraph 8 and, on that basis, denies the allegations.
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`9.
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`MMF admits that this Court has personal jurisdiction over MMF. MMF admits
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`that it offers for sale and has sold its products throughout the United States, including to
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`2
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`Patent Owner adidas AG
`Exhibit 2021 - Page 2 of 152
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`

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`Case 1:14-cv-00130-GMS Document 170 Filed 06/30/15 Page 3 of 72 PageID #: 7960
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`individuals in this District. Except as so expressly admitted herein, MMF denies the allegations
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`in Paragraph 9.
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`10. MMF admits that Venue is proper as to MMF under 28 U.S.C. §§ 1391 and
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`1400(b), but denies that it has committed any acts of infringement within this District and
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`specifically denies any wrongdoing, infringement, inducement of infringement, or contribution
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`to infringement.
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`THE PATENTS
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`11. MMF admits that U.S. Patent No. 7,292,867 (“the ’867 patent”) on its face recites
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`an issue date of November 6, 2007 and bears the title “Location-aware fitness training device,
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`methods, and program products that support real-time interactive communication and automated
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`route generation.” MMF admits that a copy of the ’867 patent was attached to the Complaint as
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`Exhibit A. MMF lacks information sufficient to form a belief as to the truth of the allegation
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`concerning Plaintiff’s purported ownership of the ’867 patent. MMF denies that the ’867 patent
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`was duly and legally issued. MMF denies that Plaintiff is entitled to any damages. Except as so
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`expressly admitted herein, MMF denies the allegations in Paragraph 11.
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`12. MMF admits that U.S. Patent No. 7,805,149 (“the ’149 patent”) on its face recites
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`an issue date of September 28, 2010 and bears the title “Location-aware fitness training device,
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`methods, and program products that support real-time interactive communication and automated
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`route generation.” MMF admits that a copy of the ’149 patent was attached to the Complaint as
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`Exhibit B. MMF lacks information sufficient to form a belief as to the truth of the allegation
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`concerning Plaintiff’s purported ownership of the ’149 patent. MMF denies that the ’149 patent
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`was duly and legally issued. MMF denies that Plaintiff is entitled to any damages. Except as so
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`expressly admitted herein, MMF denies the allegations in Paragraph 12.
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`3
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`Patent Owner adidas AG
`Exhibit 2021 - Page 3 of 152
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`

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`Case 1:14-cv-00130-GMS Document 170 Filed 06/30/15 Page 4 of 72 PageID #: 7961
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`13. MMF admits that U.S. Patent No. 7,941,160 (“the ’160 patent”) on its face recites
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`an issue date of May 10, 2011 and bears the title “Location-aware fitness training device,
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`methods, and program products that support real-time interactive communication and automated
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`route generation.” MMF admits that a copy of the ’160 patent was attached to the Complaint as
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`Exhibit C. MMF lacks information sufficient to form a belief as to the truth of the allegation
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`concerning Plaintiff’s purported ownership of the ’160 patent. MMF denies that the ’160 patent
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`was duly and legally issued. MMF denies that Plaintiff is entitled to any damages. Except as so
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`expressly admitted herein, MMF denies the allegations in Paragraph 13.
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`14. MMF admits that U.S. Patent No. 7,957,752 (“the ’752 patent”) on its face recites
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`an issue date of June 7, 2011 and bears the title “Location-aware fitness training device,
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`methods, and program products that support real-time interactive communication and automated
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`route generation.” MMF admits that a copy of the ’752 patent was attached to the Complaint as
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`Exhibit D. MMF lacks information sufficient to form a belief as to the truth of the allegation
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`concerning Plaintiff’s purported ownership of the ’752 patent. MMF denies that the ’752 patent
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`was duly and legally issued. MMF denies that Plaintiff is entitled to any damages. Except as so
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`expressly admitted herein, MMF denies the allegations in Paragraph 14.
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`15. MMF admits that U.S. Patent No. 8,068,858 (“the ’858 patent”) on its face recites
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`an issue date of November 29, 2011 and bears the title “Methods and computer program products
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`for providing information about a user during physical activity.” MMF admits that a copy of the
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`’858 patent was attached to the Complaint as Exhibit E. MMF lacks information sufficient to
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`form a belief as to the truth of the allegation concerning Plaintiff’s purported ownership of the
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`’858 patent. MMF denies that the ’858 patent was duly and legally issued. MMF denies that
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`4
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`Patent Owner adidas AG
`Exhibit 2021 - Page 4 of 152
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`

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`Case 1:14-cv-00130-GMS Document 170 Filed 06/30/15 Page 5 of 72 PageID #: 7962
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`Plaintiff is entitled to any damages. Except as so expressly admitted herein, MMF denies the
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`allegations in Paragraph 15.
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`16. MMF admits that U.S. Patent No. 8,244,226 (“the ’226 patent”) on its face recites
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`an issue date of August 14, 2012 and bears the title “Systems and methods for presenting
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`characteristics associated with a physical activity route.” MMF lacks information sufficient to
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`form a belief as to the truth of the allegation concerning Plaintiff’s purported ownership of the
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`’226 patent. MMF denies that the ’226 patent was duly and legally issued. MMF denies that
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`Plaintiff is entitled to any damages. Except as so expressly admitted herein, MMF denies the
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`allegations in Paragraph 16.
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`17. MMF admits that U.S. Patent No. 7,905,815 (“the ’815 patent”) on its face recites
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`an issue date of March 15, 2011 and bears the title “Personal data collection systems and
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`methods.” MMF admits that a copy of the ’815 patent was attached to the Complaint as Exhibit
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`G. MMF lacks information sufficient to form a belief as to the truth of the allegation concerning
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`Plaintiff’s purported ownership of the ’815 patent. MMF denies that the ’815 patent was duly
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`and legally issued. MMF denies that Plaintiff is entitled to any damages. Except as so expressly
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`admitted herein, MMF denies the allegations in Paragraph 17.
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`18. MMF admits that U.S. Patent No. 7,931,562 (“the ’562 patent”) on its face recites
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`an issue date of April 26, 2011 and bears the title “Mobile data logging systems and methods.”
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`MMF admits that a copy of the ’562 patent was attached to the Complaint as Exhibit H. MMF
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`lacks information sufficient to form a belief as to the truth of the allegation concerning Plaintiff’s
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`purported ownership of the ’562 patent. MMF denies that the ’562 patent was duly and legally
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`issued. MMF denies that Plaintiff is entitled to any damages. Except as so expressly admitted
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`herein, MMF denies the allegations in Paragraph 18.
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`5
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`Patent Owner adidas AG
`Exhibit 2021 - Page 5 of 152
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`

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`Case 1:14-cv-00130-GMS Document 170 Filed 06/30/15 Page 6 of 72 PageID #: 7963
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`19. MMF admits that U.S. Patent No. 8,092,345 (“the ’345 patent”) on its face recites
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`an issue date of January 10, 2012 and bears the title “Systems and methods for a portable
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`electronic journal.” MMF admits that a copy of the ’345 patent was attached to the Complaint as
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`Exhibit I. MMF lacks information sufficient to form a belief as to the truth of the allegation
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`concerning Plaintiff’s purported ownership of the ’345 patent. MMF denies that the ’345 patent
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`was duly and legally issued. MMF denies that Plaintiff is entitled to any damages. Except as so
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`expressly admitted herein, MMF denies the allegations in Paragraph 19.
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`20. MMF admits that U.S. Patent No. 8,579,767 (“the ’767 patent”) on its face recites
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`an issue date of November 12, 2013 and bears the title “Performance monitoring apparatuses,
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`methods, and computer program products.” MMF admits that a copy of the ’767 patent was
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`attached to the Complaint as Exhibit J. MMF lacks information sufficient to form a belief as to
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`the truth of the allegation concerning Plaintiff’s purported ownership of the ’767 patent. MMF
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`denies that the ’767 patent was duly and legally issued. MMF denies that Plaintiff is entitled to
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`any damages. Except as so expressly admitted herein, MMF denies the allegations in Paragraph
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`20.
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`21. MMF admits that U.S. Patent No. 8,725,276 (“the ’276 patent”) on its face recites
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`an issue date of May 13, 2014 and bears the title “Performance Monitoring Methods.” MMF
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`admits that a copy of the ’276 patent was attached to the Complaint as Exhibit K. MMF lacks
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`information sufficient to form a belief as to the truth of the allegation concerning Plaintiff’s
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`purported ownership of the ’276 patent. MMF denies that the ’276 patent was duly and legally
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`issued. MMF denies that Plaintiff is entitled to any damages. Except as so expressly admitted
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`herein, MMF denies the allegations in Paragraph 21.
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`6
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`Patent Owner adidas AG
`Exhibit 2021 - Page 6 of 152
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`

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`Case 1:14-cv-00130-GMS Document 170 Filed 06/30/15 Page 7 of 72 PageID #: 7964
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`22. MMF admits that U.S. Patent No. 8,721,502 (“the ’502 patent”) on its face recites
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`an issue date of May 13, 2014 and bears the title “Systems and methods for displaying
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`performance information.” MMF admits that a copy of the ’502 patent was attached to the
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`Complaint as Exhibit L. MMF lacks information sufficient to form a belief as to the truth of the
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`allegation concerning Plaintiff’s purported ownership of the ’502 patent. MMF denies that the
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`’502 patent was duly and legally issued. MMF denies that Plaintiff is entitled to any damages.
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`Except as so expressly admitted herein, MMF denies the allegations in Paragraph 22.
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`23. MMF admits that U.S. Patent No. 8,652,009 (“the ’009 patent”) on its face recites
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`an issue date of February 18, 2014 and bears the title “Modular personal network system and
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`methods.” MMF admits that a copy of the ’009 patent was attached to the Complaint as Exhibit
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`M. MMF lacks information sufficient to form a belief as to the truth of the allegation concerning
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`Plaintiff’s purported ownership of the ’009 patent. MMF denies that the ’009 patent was duly
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`and legally issued. MMF denies that Plaintiff is entitled to any damages. Except as so expressly
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`admitted herein, MMF denies the allegations in Paragraph 23.
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`24. MMF denies the allegations in Paragraph 24 of the Complaint.
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`GENERAL ALLEGATIONS
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`25. MMF admits that Under Armour’s products include Armour39®. MMF lacks
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`information sufficient to form a belief as to the truth of any remaining allegations in Paragraph
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`25 of the Complaint, and therefore denies them.
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`26. MMF admits that Under Armour’s products include Armour39®. MMF lacks
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`information sufficient to form a belief as to the truth of any remaining allegations in Paragraph
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`26 of the Complaint, and therefore denies them.
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`7
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`Patent Owner adidas AG
`Exhibit 2021 - Page 7 of 152
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`

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`Case 1:14-cv-00130-GMS Document 170 Filed 06/30/15 Page 8 of 72 PageID #: 7965
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`27. MMF admits that Under Armour’s products include Armour39®. MMF lacks
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`information sufficient to form a belief as to the truth of any remaining allegations in Paragraph
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`27 of the Complaint, and therefore denies them.
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`28. MMF admits that Under Armour’s products include Armour39®. MMF lacks
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`information sufficient to form a belief as to the truth of any remaining allegations in Paragraph
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`28 of the Complaint, and therefore denies them.
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`29. MMF admits that Under Armour’s products include Armour39®. MMF lacks
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`information sufficient to form a belief as to the truth of any remaining allegations in Paragraph
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`29 of the Complaint, and therefore denies them.
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`30. MMF admits that Under Armour’s products include Armour39®. MMF lacks
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`information sufficient to form a belief as to the truth of any remaining allegations in Paragraph
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`30 of the Complaint, and therefore denies them.
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`31. MMF admits that MMF’s products include MapMyFitness, MapMyWalk,
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`MapMyHike, MapMyRun, MapMyRide, MapMyFitness+, MapMyWalk+, MapMyHike+,
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`MapMyRun+, MapMyRide+, and MapMyDogwalk. MMF lacks information sufficient to form a
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`belief as to the truth of the remaining allegations in Paragraph 31 of the Complaint, and therefore
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`denies them.
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`32. MMF admits that MMF’s products include MapMyFitness, MapMyWalk,
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`MapMyHike, MapMyRun, MapMyRide, MapMyFitness+, MapMyWalk+, MapMyHike+,
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`MapMyRun+, MapMyRide+, and MapMyDogwalk. MMF lacks information sufficient to form a
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`belief as to the truth of the remaining allegations in Paragraph 32 of the Complaint, and therefore
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`denies them.
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`8
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`Patent Owner adidas AG
`Exhibit 2021 - Page 8 of 152
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`

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`Case 1:14-cv-00130-GMS Document 170 Filed 06/30/15 Page 9 of 72 PageID #: 7966
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`33. MMF admits that MMF’s products include MapMyFitness, MapMyWalk,
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`MapMyHike, MapMyRun, MapMyRide, MapMyFitness+, MapMyWalk+, MapMyHike+,
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`MapMyRun+, MapMyRide+, and MapMyDogwalk. MMF lacks information sufficient to form a
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`belief as to the truth of the remaining allegations in Paragraph 33 of the Complaint and therefore
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`denies them.
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`34. MMF admits that MMF’s products include MapMyFitness, MapMyWalk,
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`MapMyHike, MapMyRun, MapMyRide, MapMyFitness+, MapMyWalk+, MapMyHike+,
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`MapMyRun+, MapMyRide+, and MapMyDogwalk. MMF lacks information sufficient to form a
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`belief as to the truth of the remaining allegations in Paragraph 34 of the Complaint and therefore
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`denies them.
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`35. MMF admits that MMF’s products include MapMyFitness, MapMyWalk,
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`MapMyHike, MapMyRun, MapMyRide, MapMyFitness+, MapMyWalk+, MapMyHike+,
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`MapMyRun+, MapMyRide+, and MapMyDogwalk. MMF lacks information sufficient to form a
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`belief as to the truth of the remaining allegations in Paragraph 35 of the Complaint and therefore
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`denies them.
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`36. MMF admits that MMF’s products include MapMyFitness, MapMyWalk,
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`MapMyHike, MapMyRun, MapMyRide, MapMyFitness+, MapMyWalk+, MapMyHike+,
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`MapMyRun+, MapMyRide+, and MapMyDogwalk. MMF lacks information sufficient to form a
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`belief as to the truth of the remaining allegations in Paragraph 36 of the Complaint and therefore
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`denies them.
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`37. MMF admits that MMF’s products include MapMyFitness, MapMyWalk,
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`MapMyHike, MapMyRun, MapMyRide, MapMyFitness+, MapMyWalk+, MapMyHike+,
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`MapMyRun+, MapMyRide+, and MapMyDogwalk. MMF lacks information sufficient to form
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`9
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`Patent Owner adidas AG
`Exhibit 2021 - Page 9 of 152
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`

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`Case 1:14-cv-00130-GMS Document 170 Filed 06/30/15 Page 10 of 72 PageID #: 7967
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`a belief as to the truth of the remaining allegations in Paragraph 37 of the Complaint and
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`therefore denies them.
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`38. MMF admits that MMF’s products include MapMyFitness, MapMyWalk,
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`MapMyHike, MapMyRun, MapMyRide, MapMyFitness+, MapMyWalk+, MapMyHike+,
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`MapMyRun+, MapMyRide+, and MapMyDogwalk. MMF lacks information sufficient to form a
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`belief as to the truth of the remaining allegations in Paragraph 38 of the Complaint and therefore
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`denies them.
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`39. MMF admits that MMF’s products include MapMyFitness, MapMyWalk,
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`MapMyHike, MapMyRun, MapMyRide, MapMyFitness+, MapMyWalk+, MapMyHike+,
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`MapMyRun+, MapMyRide+, and MapMyDogwalk. MMF lacks information sufficient to form a
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`belief as to the truth of the remaining allegations in Paragraph 39 of the Complaint and therefore
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`denies them.
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`40. MMF admits that MMF’s products include MapMyFitness, MapMyWalk,
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`MapMyHike, MapMyRun, MapMyRide, MapMyFitness+, MapMyWalk+, MapMyHike+,
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`MapMyRun+, MapMyRide+, and MapMyDogwalk. MMF lacks information sufficient to form a
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`belief as to the truth of the remaining allegations in Paragraph 40 of the Complaint and therefore
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`denies them.
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`41. MMF admits that MMF’s products include MapMyFitness, MapMyWalk,
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`MapMyHike, MapMyRun, MapMyRide, MapMyFitness+, MapMyWalk+, MapMyHike+,
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`MapMyRun+, MapMyRide+, and MapMyDogwalk. MMF lacks information sufficient to form a
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`belief as to the truth of the remaining allegations in Paragraph 41 of the Complaint and therefore
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`denies them.
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`10
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`Patent Owner adidas AG
`Exhibit 2021 - Page 10 of 152
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`

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`Case 1:14-cv-00130-GMS Document 170 Filed 06/30/15 Page 11 of 72 PageID #: 7968
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`42. MMF admits that the Under Armour Connected Fitness suite is available through
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`the MMF website. MMF lacks information sufficient to form a belief as to the truth of the
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`remaining allegations in Paragraph 42 of the Complaint and therefore denies them.
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`43. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 43 of the Complaint and therefore denies them.
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`44. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 44 of the Complaint and therefore denies them.
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`45. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 45 of the Complaint and therefore denies them.
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`46. MMF admits that Plaintiff accurately quoted text from
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`http://www.uabiz.com/releasedetail.cfm?ReleaseID=807138, which is dated November 14, 2013,
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`and announces the acquisition by Under Armour of MMF. MMF otherwise denies Plaintiff’s
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`characterization of this text, and on that basis, MMF denies the remaining allegations in
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`Paragraph 46 of the Complaint.
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`47. MMF admits that Plaintiff accurately quotes text from
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`http://www.uabiz.com/releasedetail.cfm?ReleaseID=807138, which is dated November 14, 2013,
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`and announces the acquisition by Under Armour of MapMyFitness. MMF otherwise denies how
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`Plaintiff has characterized this text, and on that basis, MMF denies the remaining allegations in
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`Paragraph 47 of the Complaint.
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`48. MMF denies that “Under Armour and MMF communicated about relevant
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`industry patent rights” and therefore also denies that MMF took any action as a result thereof.
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`MMF admits that it provided certain indemnifications and warranties to Under Armour. MMF
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`11
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`Patent Owner adidas AG
`Exhibit 2021 - Page 11 of 152
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`Case 1:14-cv-00130-GMS Document 170 Filed 06/30/15 Page 12 of 72 PageID #: 7969
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`otherwise lacks information sufficient to form a belief as to the truth of the allegations in
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`Paragraph 48 of the Complaint and therefore denies them.
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`49. MMF admits that it learned of the asserted patents upon service of the Second
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`Amended Complaint and the original Complaint. MMF otherwise lacks information sufficient to
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`form a belief as to the truth of any remaining allegations in Paragraph 49 of the Complaint and
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`therefore denies them.
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`50. MMF admits that http://about.mapmyfitness.com/2013/11/underarmour is dated
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`November 14, 2013, and announces Under Armour’s acquisition of MMF. MMF otherwise lacks
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`information sufficient to form a belief as to the truth of the allegations in Paragraph 50 of the
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`Complaint and therefore denies them.
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`RESPONSE TO COUNT I
`(ALLEGED INFRINGEMENT OF U.S. PATENT NO. 7,292,867 BY UNDER ARMOUR)
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`51. MMF hereby incorporates its responses to Paragraphs 1-50 of the Complaint.
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`52. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 52 of the Complaint, and therefore denies them.
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`53. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 53 of the Complaint, and therefore denies them.
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`54. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 54 of the Complaint, and therefore denies them.
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`55. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 55 of the Complaint, and therefore denies them.
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`56. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 56 of the Complaint, and therefore denies them.
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`12
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`Patent Owner adidas AG
`Exhibit 2021 - Page 12 of 152
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`Case 1:14-cv-00130-GMS Document 170 Filed 06/30/15 Page 13 of 72 PageID #: 7970
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`57. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 57 of the Complaint, and therefore denies them.
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`RESPONSE TO COUNT II
`(ALLEGED INFRINGEMENT OF U.S. PATENT NO. 7,805,149 BY UNDER ARMOUR)
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`58. MMF hereby incorporates its responses to Paragraphs 1-57 of the Complaint.
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`59. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 59 of the Complaint, and therefore denies them.
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`60. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 60 of the Complaint, and therefore denies them.
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`61. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 61 of the Complaint, and therefore denies them.
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`62. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 62 of the Complaint, and therefore denies them.
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`63. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 63 of the Complaint, and therefore denies them.
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`64. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 64 of the Complaint, and therefore denies them.
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`RESPONSE TO COUNT III
`(ALLEGED INFRINGEMENT OF U.S. PATENT NO. 7,941,160 BY UNDER ARMOUR)
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`65. MMF hereby incorporates its responses to Paragraphs 1-64 of the Complaint.
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`66. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 66 of the Complaint, and therefore denies them.
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`67. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 67 of the Complaint, and therefore denies them.
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`13
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`Patent Owner adidas AG
`Exhibit 2021 - Page 13 of 152
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`

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`Case 1:14-cv-00130-GMS Document 170 Filed 06/30/15 Page 14 of 72 PageID #: 7971
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`68. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 68 of the Complaint, and therefore denies them.
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`69. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 69 of the Complaint, and therefore denies them.
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`70. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 70 of the Complaint, and therefore denies them.
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`71. MMF lacks information sufficient to form a belief as to the truth of the allegations
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`in Paragraph 71 of the Complaint, and therefore denies them.
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`RESPONSE TO COUNT IV
`(ALLEGED INFRINGEMENT OF U.S. PATENT NO. 7,957,752 BY UNDER ARMOUR)
`
`72. MMF hereby incorporates its responses to Paragraphs 1-71 of the Complaint.
`
`73. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 73 of the Complaint, and therefore denies them.
`
`74. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 74 of the Complaint, and therefore denies them.
`
`75. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 75 of the Complaint, and therefore denies them.
`
`76. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 76 of the Complaint, and therefore denies them.
`
`77. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 77 of the Complaint, and therefore denies them.
`
`RESPONSE TO COUNT V
`(ALLEGED INFRINGEMENT OF U.S. PATENT NO. 8,068,858 BY UNDER ARMOUR)
`
`78. MMF hereby incorporates its responses to Paragraphs 1-77 of the Complaint.
`
`14
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`Patent Owner adidas AG
`Exhibit 2021 - Page 14 of 152
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`

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`Case 1:14-cv-00130-GMS Document 170 Filed 06/30/15 Page 15 of 72 PageID #: 7972
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`79. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 79 of the Complaint, and therefore denies them.
`
`80. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 80 of the Complaint, and therefore denies them.
`
`81. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 81 of the Complaint, and therefore denies them.
`
`82. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 82 of the Complaint, and therefore denies them.
`
`83. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 83 of the Complaint, and therefore denies them.
`
`RESPONSE TO COUNT VI
`(ALLEGED INFRINGEMENT OF U.S. PATENT NO. 7,905,815 BY UNDER ARMOUR)
`
`84. MMF hereby incorporates its responses to Paragraphs 1-83 of the Complaint.
`
`85. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 85 of the Complaint, and therefore denies them.
`
`86. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 86 of the Complaint, and therefore denies them.
`
`87. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 87 of the Complaint, and therefore denies them.
`
`88. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 88 of the Complaint, and therefore denies them.
`
`89. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 89 of the Complaint, and therefore denies them.
`
`15
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`Patent Owner adidas AG
`Exhibit 2021 - Page 15 of 152
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`

`
`Case 1:14-cv-00130-GMS Document 170 Filed 06/30/15 Page 16 of 72 PageID #: 7973
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`90. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 90 of the Complaint, and therefore denies them.
`
`RESPONSE TO COUNT VII
`(ALLEGED INFRINGEMENT OF U.S. PATENT NO. 8,244,226 BY UNDER ARMOUR)
`
`91. MMF hereby incorporates its responses to Paragraphs 1-90 of the Complaint.
`
`92. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 92 of the Complaint, and therefore denies them.
`
`93. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 93 of the Complaint, and therefore denies them.
`
`94. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 94 of the Complaint, and therefore denies them.
`
`95. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 95 of the Complaint, and therefore denies them.
`
`96. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 96 of the Complaint, and therefore denies them.
`
`97. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 97 of the Complaint, and therefore denies them.
`
`RESPONSE TO COUNT VIII
`(ALLEGED INFRINGEMENT OF U.S. PATENT NO. 7,931,562 BY UNDER ARMOUR)
`
`98. MMF hereby incorporates its responses to Paragraphs 1-97 of the Complaint.
`
`99. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 99 of the Complaint, and therefore denies them.
`
`100. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 100 of the Complaint, and therefore denies them.
`
`16
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`Patent Owner adidas AG
`Exhibit 2021 - Page 16 of 152
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`

`
`Case 1:14-cv-00130-GMS Document 170 Filed 06/30/15 Page 17 of 72 PageID #: 7974
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`101. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 101 of the Complaint, and therefore denies them.
`
`102. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 102 of the Complaint, and therefore denies them.
`
`103. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 103 of the Complaint, and therefore denies them.
`
`104. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 104 of the Complaint, and therefore denies them.
`
`RESPONSE TO COUNT IX
`(ALLEGED INFRINGEMENT OF U.S. PATENT NO. 8,092,345 BY UNDER ARMOUR)
`
`105. MMF hereby incorporates its responses to Paragraphs 1-104 of the Complaint.
`
`106. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 106 of the Complaint, and therefore denies them.
`
`107. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 107 of the Complaint, and therefore denies them.
`
`108. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 108 of the Complaint, and therefore denies them.
`
`109. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 109 of the Complaint, and therefore denies them.
`
`110. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 110 of the Complaint, and therefore denies them.
`
`111. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 111 of the Complaint, and therefore denies them.
`
`RESPONSE TO COUNT X
`
`17
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`Patent Owner adidas AG
`Exhibit 2021 - Page 17 of 152
`
`

`
`Case 1:14-cv-00130-GMS Document 170 Filed 06/30/15 Page 18 of 72 PageID #: 7975
`
`(ALLEGED INFRINGEMENT OF U.S. PATENT NO. 8,579,767 BY UNDER ARMOUR)
`
`112. MMF hereby incorporates its responses to Paragraphs 1-111 of the Complaint.
`
`113. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 113 of the Complaint, and therefore denies them.
`
`114. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 114 of the Complaint, and therefore denies them.
`
`115. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 115 of the Complaint, and therefore denies them.
`
`116. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 116 of the Complaint, and therefore denies them.
`
`117. MMF lacks information sufficient to form a belief as to the truth of the allegations
`
`in Paragraph 117 of the Complaint, and therefore denies them.
`
`118. MMF lacks information sufficient to form a belief as to the truth of the allegation