Case 6:22-cv-00031-ADA Document 55 Filed 09/20/22 Page 1 of 24
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`FLYPSI, INC., (D/B/A FLYP),
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`Plaintiff,
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`v.
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`GOOGLE LLC,
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`Defendant.
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`
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`CIVIL ACTION NO. 6:22-cv-00031-ADA
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`JURY TRIAL DEMANDED
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`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
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`DEFENDANT’S ANSWER TO
`FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT
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`Defendant Google LLC (“Google”) hereby submits its Answer in response to the First
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`Amended Complaint for Patent Infringement (“FAC”) filed by Plaintiff Flypsi, Inc. (D/B/A
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`Flyp) (“Flyp”) as set forth below.
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`Each paragraph of the Answer below corresponds to the corresponding numbered or
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`lettered paragraph of the FAC. All allegations not expressly admitted herein are denied by
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`Defendant.
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`THE PARTIES1
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`1.
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`Defendant lacks knowledge or information sufficient to form a belief as to the
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`truth or falsity of the allegations contained in paragraph 1, and therefore denies them.
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`2.
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`Defendant admits that Google LLC is a Delaware limited liability company with
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`office locations in Austin, Texas. Defendant admits that its registered agent in Texas is
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`Corporation Service Company, 211 East 7th Street, Suite 620, Austin, Texas 78701. Defendant
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`admits that it is registered to do business in the State of Texas and has been since at least
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`1 Headings are provided for convenience only and are not admissions.
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`

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`November 17, 2006. Except as expressly admitted, Defendant lacks knowledge or information
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`sufficient to form a belief as to the truth or falsity of the remaining allegations contained in
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`paragraph 2 of the FAC and therefore denies each and every allegation set forth therein.
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`JURISDICTION AND VENUE
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`3.
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`Defendant admits that this Court has subject matter jurisdiction over actions
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`arising under 28 U.S.C. §§ 1331 and 1338(a). Except as expressly admitted, Defendant denies
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`any remaining allegations in paragraph 3.
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`4.
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`Paragraph 4 contains legal conclusions to which no response is required. To the
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`extent a response is required, Google does not contest that venue is proper in this District for the
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`purpose of this particular action, but denies that venue is convenient or in the interests of justice
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`under 28 U.S.C. § 1404(a). Except as expressly admitted, Defendant denies any remaining
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`allegations in paragraph 4.
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`5.
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`Defendant admits that, as of the date of this Answer, the Texas report at
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`https://economicimpact.google.com/state/tx/ states: “Google has proudly called Texas home for
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`more than a decade with offices in Austin and Dallas, and a data center in Midlothian.”
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`Defendant admits that, as of the date of this Answer,
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`https://economicimpact.google.com/state/tx/ states: “In June of 2019, Google officially broke
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`ground on its $600 million data center in Midlothian, Texas.” Defendant denies any conclusions,
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`characterizations, implications, insinuations or speculations that Plaintiff alleges follow from the
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`admitted facts. Defendant admits that Google has employees and offices in Texas, including in
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`Austin, Texas. Except as expressly admitted, Defendant lacks knowledge or information
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`sufficient to form a belief as to the truth or falsity of the remaining allegations contained in
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`paragraph 5 of the FAC and therefore denies each and every allegation set forth therein.
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`Case 6:22-cv-00031-ADA Document 55 Filed 09/20/22 Page 3 of 24
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`6.
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`Defendant admits that, as of the date of this Answer,
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`https://www.statesman.com/story/business/2021/08/13/austin-google-exec-companys-future-
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`really-bright-in-city-tx/5488231001/ states: “The company opened an Austin office in 2007 and
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`now has more than 1,500 employees in Central Texas;” “Elkhiamy, who is also director of
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`Google’s corporate engineering division, said she views her role as support for 800 engineering
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`employees based in Austin, and the broader Google Austin hub;” “For Google’s Nuha Elkhiamy,
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`it’s exciting to see the company’s Austin operations grow into one of Google’s largest hubs;”
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`and “Google plans to occupy all of a new 35-story tower being built at 601 W. Second St.”
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`Defendant denies any conclusions, characterizations, implications, insinuations or speculations
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`that Plaintiff alleges follow from the admitted fact. Defendant admits that, as of the date of this
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`Answer, https://www.kvue.com/article/money/economy/boomtown-2040/google-austin-texas-
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`real-estate-report/269-2ce6e60e-e8c3-46f5-aca6-864175e67950 states: “Google said it owns
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`550,000 square feet worth of office spaces in Downtown Austin at its three locations: 100
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`Congress Ave., 901 E. Fifth St. and 500 W. Second St. Meanwhile, the company said another
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`750,000 square feet of office space is scheduled to open in 2023 at 601 W. Second St.”
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`Defendant denies any conclusions, characterizations, implications, insinuations or speculations
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`that Plaintiff alleges follow from the admitted facts. Except as expressly admitted, Defendant
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`lacks knowledge or information sufficient to form a belief as to the truth or falsity of the
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`remaining allegations contained in paragraph 6 of the FAC and therefore denies each and every
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`allegation set forth therein.
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`7.
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`Paragraph 7 contains legal conclusions to which no response is required. To the
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`extent a response is required, Defendant admits that Google has employees and offices in Texas,
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`including in Austin, Texas. Defendant admits, as of the date of this Answer,
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`-3-
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`Case 6:22-cv-00031-ADA Document 55 Filed 09/20/22 Page 4 of 24
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`https://fiber.google.com/phone/ states: “Google Fiber Phone is just like a typical home phone,
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`except your phone service is delivered over the Internet, and it’s powered by Google Voice. Use
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`your current home phone number, choose a new one, or use your existing Google Voice
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`number.” Defendant denies any conclusions, characterizations, implications, insinuations or
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`speculations that Plaintiff alleges follow from the admitted facts. Defendant specifically denies
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`that Google has committed or is committing any acts of infringement as alleged by Plaintiff in
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`this or any other District. Except as expressly admitted, Defendant lacks knowledge or
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`information sufficient to form a belief as to the truth or falsity of the remaining allegations
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`contained in paragraph 7 of the FAC and therefore denies each and every allegation set forth
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`therein.
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`8.
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`Defendant admits that, as of the date of this Answer, https://careers.google.com/
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`lists jobs available in Austin, Texas, and other locations. Except as expressly admitted,
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`Defendant lacks knowledge or information sufficient to form a belief as to the truth or falsity of
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`the remaining allegations contained in paragraph 8 of the FAC and therefore denies each and
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`every allegation set forth therein.
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`9.
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`Defendant admits that it has a data center located in Midlothian, Texas. Defendant
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`admits that, as of the date of this Answer,
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`https://www.google.com/about/datacenters/locations/midlothian/ states: “In June of 2019,
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`Google officially broke ground on its $600 million data center in Midlothian, Texas.” Defendant
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`denies any conclusions, characterizations, implications, insinuations or speculations that Plaintiff
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`alleges follow from the admitted facts. Defendant admits that, as of the date of this Answer,
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`https://www.dallasnews.com/business/real-estate/2019/06/14/google-s-massive-600m-data-
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`center-takes-shape-in-ellis-county-as-tech-giant-ups-texas-presence/ states: “‘Data centers are
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`-4-
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`Case 6:22-cv-00031-ADA Document 55 Filed 09/20/22 Page 5 of 24
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`really the engine of the internet. Anytime you process an email on Gmail or look at a cat video
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`on YouTube, it’s going through a data center,’ Silvestri said. ‘If you are living in Texas or
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`surrounding areas, it will likely be processed in that center.’” Defendant denies any conclusions,
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`characterizations, implications, insinuations or speculations that Plaintiff alleges follow from the
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`admitted facts. Defendant admits that a court has found that its Midlothian, Texas data center is
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`“outside of the Western District of Texas but is within 100 miles of the federal courthouse in
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`Waco, Texas.” In re Google LLC, No. 2021-170, 2021 U.S. App. LEXIS 29137, at *4 (Fed. Cir.
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`Sep. 27, 2021). Except as expressly admitted, Defendant lacks knowledge or information
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`sufficient to form a belief as to the truth or falsity of the remaining allegations contained in
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`paragraph 9 of the FAC and therefore denies each and every allegation set forth therein.
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`10.
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`Paragraph 10 contains legal conclusions to which no response is required. To the
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`extent a response is required, Defendant does not contest personal jurisdiction in this District
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`solely for the purposes of this particular action. Defendant denies that Google has committed acts
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`of infringement within the Western District of Texas, or any other District. Except as expressly
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`admitted, Defendant denies any remaining allegations in paragraph 10.
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`The Flyp Inventions
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`BACKGROUND
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`11.
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`Paragraph 11 contains opinions and characterizations to which no response is
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`required. To the extent a response is required, Defendant lacks knowledge or information
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`sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 11 of
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`the FAC and therefore denies each and every allegation set forth therein.
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`12.
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`Paragraph 12 contains opinions and characterizations to which no response is
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`required. To the extent a response is required, Defendant lacks knowledge or information
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`-5-
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`Case 6:22-cv-00031-ADA Document 55 Filed 09/20/22 Page 6 of 24
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`sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 12 of
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`the FAC and therefore denies each and every allegation set forth therein.
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`13.
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`Paragraph 13 contains opinions and characterizations to which no response is
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`required. To the extent a response is required, Defendant lacks knowledge or information
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`sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 13 of
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`the FAC and therefore denies each and every allegation set forth therein.
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`14.
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`Paragraph 14 contains opinions and characterizations to which no response is
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`required. To the extent a response is required, Defendant lacks knowledge or information
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`sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 14 of
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`the FAC and therefore denies each and every allegation set forth therein.
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`15.
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`Paragraph 15 contains opinions and characterizations to which no response is
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`required. To the extent a response is required, Defendant lacks knowledge or information
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`sufficient to form a belief as to the truth or falsity of the allegations contained in paragraph 15 of
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`the FAC and therefore denies each and every allegation set forth therein.
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`Google Voice
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`16.
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`Defendant admits that it offers a service called Google Voice. Defendant admits
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`that Google Voice includes applications that may optionally be downloaded by a user to an iOS
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`or Android device. Except as expressly admitted, Defendant lacks knowledge or information
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`sufficient to form a belief as to the truth or falsity of the remaining allegations contained in
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`paragraph 16 of the FAC and therefore denies each and every allegation set forth therein.
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`17.
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`Paragraph 17 contains legal conclusions to which no response is required. To the
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`extent a response is required, Defendant admits that Google Voice was initially released by
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`Google in 2009. Defendant admits that Google changed certain aspects of Google Voice in or
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`around 2017. Except as expressly admitted, Defendant lacks knowledge or information sufficient
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`-6-
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`to form a belief as to the truth or falsity of the remaining allegations contained in paragraph 17 of
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`the FAC and therefore denies each and every allegation set forth therein.
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`18.
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`Defendant admits that, as of the date of this Answer,
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`https://www.lifewire.com/what-is-googlevoice-1616888 states: “Google Voice is an internet-
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`based service that gives your contacts one voice number and forwards calls to multiple phones—
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`landline or mobile—that you specify.” Defendant denies any conclusions, characterizations,
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`implications, insinuations or speculations that Plaintiff alleges follow from the admitted fact.
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`Defendant admits that, as of the date of this Answer,
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`https://support.google.com/voice/answer/3379129?co=GENIE.Platform%3DAndroid&hl=en
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`states: “When you call someone, a US phone number might appear that’s not your number. The
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`person you call still gets a phone call from your Google Voice number.” Defendant denies any
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`conclusions, characterizations, implications, insinuations or speculations that Plaintiff alleges
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`follow from the admitted fact. Defendant admits that, as of the date of this Answer, the video at
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`https://www.youtube.com/watch?v=vDo6hkgoYXo is titled “Google Voice - Taking Calls” and
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`appears on its face to have been published on March 11, 2009. Defendant denies any
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`conclusions, characterizations, implications, insinuations or speculations that Plaintiff alleges
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`follow from the admitted fact. Except as expressly admitted, Defendant lacks knowledge or
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`information sufficient to form a belief as to the truth or falsity of the remaining allegations
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`contained in paragraph 18 of the FAC and therefore denies each and every allegation set forth
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`therein.
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`19.
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`Defendant admits that, as of the date of this Answer, https://gizmodo.com/five-
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`years-later-google-finally-remembers-google-voice-1791532022 states: “Unfortunately, over the
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`years, Google let the nifty little voice service fall into relative disrepair—until today, that is. For
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`-7-
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`the first time in five—yes, five—years, Google Voice is getting a major UI update.” Defendant
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`denies any conclusions, characterizations, implications, insinuations or speculations that Plaintiff
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`alleges follow from the admitted fact. Except as expressly admitted, Defendant lacks knowledge
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`or information sufficient to form a belief as to the truth or falsity of the remaining allegations
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`contained in paragraph 19 of the FAC and therefore denies each and every allegation set forth
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`therein.
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`20.
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`Defendant admits that the face of the ’770, ’105, and ’094 Patents list Peter A.
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`Rinfret as a named inventor, and that the face of the ’554 and ’585 Patents list Peter Rinfret as a
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`named inventor. Defendant admits that, in or around November 2015, a meeting was scheduled
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`between Rich Miner and Peter Rinfret. Defendant admits that Rich Miner met with Peter Rinfret
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`on or about November 12, 2015 and that, on or about November 16, 2015, Mr. Miner received a
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`slide deck that mentioned Flyp’s alleged technology, business, and certain patent filings.
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`Defendant lacks knowledge or information sufficient to form a belief as to the truth or falsity of
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`any remaining allegations contained in paragraph 20, and therefore denies them.
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`21.
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`Paragraph 21 contains legal conclusions to which no response is required. To the
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`extent a response is required, Defendant admits that Google changed certain aspects of Google
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`Voice in or around 2017. Defendant specifically denies that Google has committed or is
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`committing any acts of infringement. Except as expressly admitted, Defendant lacks knowledge
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`or information sufficient to form a belief as to the truth or falsity of the remaining allegations
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`contained in paragraph 21 of the FAC and therefore denies each and every allegation set forth
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`therein.
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`-8-
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`22.
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`Defendant lacks knowledge or information sufficient to form a belief as to the
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`truth or falsity of the allegations contained in paragraph 22 of the FAC and therefore denies each
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`and every allegation set forth therein.
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`23.
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`Defendant lacks knowledge or information sufficient to form a belief as to the
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`truth or falsity of the allegations contained in paragraph 23 of the FAC and therefore denies each
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`and every allegation set forth therein.
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`THE ASSERTED PATENTS
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`24.
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`Defendant admits that the title appearing on the face of U.S. Patent No. 9,667,770
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`(“the ’770 patent”) is “Telephone Network System and Method.” Defendant admits that the ’770
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`patent bears, on its face, an issue date of May 30, 2017. Defendant admits that the ’770 patent
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`lists, on its face, named inventors by the names of Ivan Zhidov, Peter A. Rinfret, and Sunir
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`Kochhar. Defendant lacks knowledge or information sufficient to form a belief as to the truth or
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`falsity of the remaining allegations contained in paragraph 24, and therefore denies them.
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`25.
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`Defendant admits that the title appearing on the face of U.S. Patent No.
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`10,051,105 (“the ’105 patent”) is “Telephone Network System and Method.” Defendant admits
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`that the ’105 patent bears, on its face, an issue date of August 14, 2018. Defendant admits that
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`the ’105 patent lists, on its face, named inventors by the names of Ivan Zhidov, Peter A. Rinfret,
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`and Sunir Kochhar. Defendant lacks knowledge or information sufficient to form a belief as to
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`the truth or falsity of the remaining allegations contained in paragraph 25, and therefore denies
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`them.
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`26.
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`Defendant admits that the title appearing on the face of U.S. Patent No.
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`10,334,094 (“the ’094 patent”) is “Telephone Network System and Method.” Defendant admits
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`that the ’094 patent bears, on its face, an issue date of June 25, 2019. Defendant admits that the
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`’094 patent lists, on its face, named inventors by the names of Ivan Zhidov, Peter A. Rinfret, and
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`-9-
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`Sunir Kochhar. Defendant lacks knowledge or information sufficient to form a belief as to the
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`truth or falsity of the remaining allegations contained in paragraph 26, and therefore denies them.
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`27.
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`Defendant admits that the title appearing on the face of U.S. Patent No.
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`11,012,554 (“the ’554 patent”) is “Telephone Network System and Methos [sic].” Defendant
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`admits that the ’554 patent bears, on its face, an issue date of May 18, 2021. Defendant admits
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`that the ’554 patent lists, on its face, named inventors by the names of Ivan Zhidov, Peter
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`Rinfret, and Sunir Kochhar. Defendant lacks knowledge or information sufficient to form a
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`belief as to the truth or falsity of the remaining allegations contained in paragraph 27, and
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`therefore denies them.
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`28.
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`Defendant admits that the title appearing on the face of U.S. Patent No.
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`11,218,585 (“the ’585 patent”) is “Telephone Network System and Method.” Defendant admits
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`that the ’585 patent bears, on its face, an issue date of January 4, 2022. Defendant admits that the
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`’585 patent lists, on its face, named inventors by the names of Ivan Zhidov, Peter Rinfret, and
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`Sunir Kochhar. Defendant lacks knowledge or information sufficient to form a belief as to the
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`truth or falsity of the remaining allegations contained in paragraph 28, and therefore denies them.
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`Count I: Claim for Patent Infringement of the ’770 Patent
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`29.
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`Defendant repeats and incorporates by reference its responses to each preceding
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`paragraph as if fully set forth herein.
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`30.
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`Paragraph 30 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Defendant denies the allegations in paragraph 30,
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`and Defendant specifically denies that Google has committed any acts of infringement.
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`31.
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`Paragraph 31 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Defendant denies the allegations in paragraph 31,
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`and Defendant specifically denies that Google has committed any acts of infringement.
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`-10-
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`32.
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`Paragraph 32 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Defendant denies the allegations in paragraph 32,
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`and Defendant specifically denies that Google has committed any acts of infringement.
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`33.
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`Paragraph 33 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Defendant admits that Mr. Rich Miner is a co-
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`founder of Android Inc. Defendant admits that Rich Miner met with Peter Rinfret on or about
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`November 12, 2015 and that, on or about November 16, 2015, Mr. Miner received a slide deck
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`that mentioned Flyp’s alleged technology, business, and certain patent filings. Defendant lacks
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`knowledge or information sufficient to form a belief as to the truth or falsity of any remaining
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`allegations contained in paragraph 33, and therefore denies them.
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`34.
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`Paragraph 34 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Defendant denies the allegations in paragraph 34,
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`and Defendant specifically denies that Google has committed any acts of infringement.
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`35.
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`Paragraph 35 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Defendant denies the allegations in paragraph 35,
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`and Defendant specifically denies that Google has committed any acts of infringement.
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`36.
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`Paragraph 36 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Defendant denies the allegations in paragraph 36,
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`and Defendant specifically denies that Google has committed any acts of infringement.
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`37.
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`38.
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`39.
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`40.
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`Defendant denies the allegations in paragraph 37.
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`Defendant denies the allegations in paragraph 38.
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`Defendant denies the allegations in paragraph 39.
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`Defendant denies the allegations in paragraph 40.
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`Count II: Claim for Patent Infringement of the ’105 Patent
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`41.
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`Defendant repeats and incorporates by reference its responses to each preceding
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`paragraph as if fully set forth herein.
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`42.
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`Paragraph 42 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Defendant denies the allegations in paragraph 42,
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`and Defendant specifically denies that Google has committed any acts of infringement.
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`43.
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`Paragraph 43 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Defendant denies the allegations in paragraph 43,
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`and Defendant specifically denies that Google has committed any acts of infringement.
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`44.
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`Paragraph 44 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Defendant denies the allegations in paragraph 44,
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`and Defendant specifically denies that Google has committed any acts of infringement.
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`45.
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`Paragraph 45 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Defendant admits that Mr. Rich Miner is a co-
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`founder of Android Inc. Defendant admits that Rich Miner met with Peter Rinfret on or about
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`November 12, 2015 and that, on or about November 16, 2015, Mr. Miner received a slide deck
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`that mentioned Flyp’s alleged technology, business, and certain patent filings. Defendant lacks
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`knowledge or information sufficient to form a belief as to the truth or falsity of any remaining
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`allegations contained in paragraph 45, and therefore denies them.
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`46.
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`Paragraph 46 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Defendant denies the allegations in paragraph 46,
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`and Defendant specifically denies that Google has committed any acts of infringement.
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`-12-
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`47.
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`Paragraph 47 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Defendant denies the allegations in paragraph 47,
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`and Defendant specifically denies that Google has committed any acts of infringement.
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`48.
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`Paragraph 48 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Defendant denies the allegations in paragraph 48,
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`and Defendant specifically denies that Google has committed any acts of infringement.
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`49.
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`50.
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`51.
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`52.
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`Defendant denies the allegations in paragraph 49.
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`Defendant denies the allegations in paragraph 50.
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`Defendant denies the allegations in paragraph 51.
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`Defendant denies the allegations in paragraph 52.
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`Count III: Claim for Patent Infringement of the ’094 Patent
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`53.
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`Defendant repeats and incorporates by reference its responses to each preceding
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`paragraph as if fully set forth herein.
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`54.
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`Paragraph 54 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Defendant denies the allegations in paragraph 54,
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`and Defendant specifically denies that Google has committed any acts of infringement.
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`55.
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`Paragraph 55 contains legal conclusions and arguments to which no response is
`
`required. To the extent a response is required, Defendant denies the allegations in paragraph 55,
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`and Defendant specifically denies that Google has committed any acts of infringement.
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`56.
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`Paragraph 56 contains legal conclusions and arguments to which no response is
`
`required. To the extent a response is required, Defendant denies the allegations in paragraph 56,
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`and Defendant specifically denies that Google has committed any acts of infringement.
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`57.
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`Paragraph 57 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Defendant admits that Mr. Rich Miner is a co-
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`-13-
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`Case 6:22-cv-00031-ADA Document 55 Filed 09/20/22 Page 14 of 24
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`founder of Android Inc. Defendant admits that Rich Miner met with Peter Rinfret on or about
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`November 12, 2015 and that, on or about November 16, 2015, Mr. Miner received a slide deck
`
`that mentioned Flyp’s alleged technology, business, and certain patent filings. Defendant lacks
`
`knowledge or information sufficient to form a belief as to the truth or falsity of any remaining
`
`allegations contained in paragraph 57, and therefore denies them.
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`58.
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`Paragraph 58 contains legal conclusions and arguments to which no response is
`
`required. To the extent a response is required, Defendant denies the allegations in paragraph 58,
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`and Defendant specifically denies that Google has committed any acts of infringement.
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`59.
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`Paragraph 59 contains legal conclusions and arguments to which no response is
`
`required. To the extent a response is required, Defendant denies the allegations in paragraph 59,
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`and Defendant specifically denies that Google has committed any acts of infringement.
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`60.
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`Paragraph 60 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Defendant denies the allegations in paragraph 60,
`
`and Defendant specifically denies that Google has committed any acts of infringement.
`
`61.
`
`62.
`
`63.
`
`64.
`
`65.
`
`66.
`
`67.
`
`Defendant denies the allegations in paragraph 61.
`
`Defendant denies the allegations in paragraph 62.
`
`Defendant denies the allegations in paragraph 63.
`
`Defendant denies the allegations in paragraph 64.
`
`Defendant denies the allegations in paragraph 65.
`
`Defendant denies the allegations in paragraph 66.
`
`Defendant denies the allegations in paragraph 67.
`
`Count IV: Claim for Patent Infringement of the ’554 Patent
`
`68.
`
`Defendant repeats and incorporates by reference its responses to each preceding
`
`paragraph as if fully set forth herein.
`
`-14-
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`

`

`Case 6:22-cv-00031-ADA Document 55 Filed 09/20/22 Page 15 of 24
`
`69.
`
`Paragraph 69 contains legal conclusions and arguments to which no response is
`
`required. To the extent a response is required, Defendant denies the allegations in paragraph 69,
`
`and Defendant specifically denies that Google has committed any acts of infringement.
`
`70.
`
`Paragraph 70 contains legal conclusions and arguments to which no response is
`
`required. To the extent a response is required, Defendant denies the allegations in paragraph 70,
`
`and Defendant specifically denies that Google has committed any acts of infringement.
`
`71.
`
`Paragraph 71 contains legal conclusions and arguments to which no response is
`
`required. To the extent a response is required, Defendant denies the allegations in paragraph 71,
`
`and Defendant specifically denies that Google has committed any acts of infringement.
`
`72.
`
`Paragraph 72 contains legal conclusions and arguments to which no response is
`
`required. To the extent a response is required, Defendant admits that Mr. Rich Miner is a co-
`
`founder of Android Inc. Defendant admits that Rich Miner met with Peter Rinfret on or about
`
`November 12, 2015 and that, on or about November 16, 2015, Mr. Miner received a slide deck
`
`that mentioned Flyp’s alleged technology, business, and certain patent filings. Defendant lacks
`
`knowledge or information sufficient to form a belief as to the truth or falsity of any remaining
`
`allegations contained in paragraph 72, and therefore denies them.
`
`73.
`
`Paragraph 73 contains legal conclusions and arguments to which no response is
`
`required. To the extent a response is required, Defendant denies the allegations in paragraph 73,
`
`and Defendant specifically denies that Google has committed any acts of infringement.
`
`74.
`
`Paragraph 74 contains legal conclusions and arguments to which no response is
`
`required. To the extent a response is required, Defendant denies the allegations in paragraph 74,
`
`and Defendant specifically denies that Google has committed any acts of infringement.
`
`-15-
`
`

`

`Case 6:22-cv-00031-ADA Document 55 Filed 09/20/22 Page 16 of 24
`
`75.
`
`Paragraph 75 contains legal conclusions and arguments to which no response is
`
`required. To the extent a response is required, Defendant denies the allegations in paragraph 75,
`
`and Defendant specifically denies that Google has committed any acts of infringement.
`
`76.
`
`77.
`
`78.
`
`79.
`
`80.
`
`81.
`
`Defendant denies the allegations in paragraph 76.
`
`Defendant denies the allegations in paragraph 77.
`
`Defendant denies the allegations in paragraph 78.
`
`Defendant denies the allegations in paragraph 79.
`
`Defendant denies the allegations in paragraph 80.
`
`Defendant denies the allegations in paragraph 81.
`
`Count [V]: Claim for Patent Infringement of the ’585 Patent
`
`82.
`
`Defendant repeats and incorporates by reference its responses to each preceding
`
`paragraph as if fully set forth herein.
`
`83.
`
`Paragraph 83 contains legal conclusions and arguments to which no response is
`
`required. To the extent a response is required, Defendant denies the allegations in paragraph 83,
`
`and Defendant specifically denies that Google has committed any acts of infringement.
`
`84.
`
`Paragraph 84 contains legal conclusions and arguments to which no response is
`
`required. To the extent a response is required, Defendant denies the allegations in paragraph 84,
`
`and Defendant specifically denies that Google has committed any acts of infringement.
`
`85.
`
`Paragraph 85 contains legal conclusions and arguments to which no response is
`
`required. To the extent a response is required, Defendant denies the allegations in paragraph 85,
`
`and Defendant specifically denies that Google has committed any acts of infringement.
`
`86.
`
`Paragraph 86 contains legal conclusions and arguments to which no response is
`
`required. To the extent a response is required, Defendant admits that Mr. Rich Miner is a co-
`
`founder of Android Inc. Defendant admits that Rich Miner met with Peter Rinfret on or about
`
`-16-
`
`

`

`Case 6:22-cv-00031-ADA Document 55 Filed 09/20/22 Page 17 of 24
`
`November 12, 2015 and that, on or about November 16, 2015, Mr. Miner received a slide deck
`
`that mentioned Flyp’s alleged technology, business, and certain patent filings. Defendant lacks
`
`knowledge or information sufficient to form a belief as to the truth or falsity of any remaining
`
`allegations contained in paragraph 86, and therefore de