PLAINTIFF’S ANSWER TO DEFENDANTS’ COUNTERCLAIMS PAGE 1

IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

WSOU INVESTMENTS, LLC d/b/a 

BRAZOS LICENSING AND 

DEVELOPMENT,

Plaintiff,

v.

HUAWEI TECHNOLOGIES CO., LTD. 

and HUAWEI TECHNOLOGIES USA 

INC.,

Defendants.

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CIVIL ACTION NO. 6:20-cv-533-ADA

JURY TRIAL DEMANDED

PLAINTIFF’S ANSWER TO DEFENDANTS’ FIRST AMENDED COUNTERCLAIMS

Plaintiff WSOU Investments, LLC d/b/a Brazos Licensing and Development hereby 

submits its Answer to Defendants’ First Amended Counterclaims (“Counterclaims”). Plaintiff 

denies all allegations in the Counterclaims not specifically admitted below. In responding to the 

Counterclaims, Plaintiff uses headings employed by Defendants strictly as a convenience to the 

Court and does not admit any allegation made in, or inference suggested by, such headings. 

Plaintiff answers the numbered paragraphs of the Counterclaims as follows:

THE PARTIES AND NATURE OF THE ACTION

1. Plaintiff admits the allegations in paragraph 1 of the Counterclaims.

2. Plaintiff admits only that Huawei Technologies USA is a corporation organized and 

existing under the laws of Texas that maintains an established place of business at 2391 NE 

Interstate 410 Loop, San Antonio, TX 78217. Otherwise, Plaintiff denies the allegations in 

paragraph 2 of the Counterclaims. 

3. Plaintiff admits the allegations in paragraph 3 of the Counterclaims.

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PLAINTIFF’S ANSWER TO DEFENDANTS’ COUNTERCLAIMS PAGE 2

4. Plaintiff admits only that the Counterclaims speak for themselves. Otherwise, 

Plaintiff denies the allegations in paragraph 4 of the Counterclaims and denies that Defendants are 

entitled to the relief they request.

JURISDICTION AND VENUE

5. Plaintiff admits that this Court has jurisdiction over Plaintiff’s claims. Otherwise, 

denied.

6. Plaintiff admits that this Court has jurisdiction over Plaintiff’s claims. Otherwise, 

denied.

7. Plaintiff admits venue is proper in this Court. Otherwise, denied.

COUNT I – DECLARATION OF INVALIDITY OF THE ’627 PATENT

8. To the extent a response is required to paragraph 8 of the Counterclaims, denied.

9. Plaintiff admits a judicial controversy has arisen concerning Defendants’ 

infringement of the patent-in-suit. Otherwise, denied.

10. Plaintiff denies the allegations in paragraph 10.

11. Plaintiff denies the allegations in paragraph 11.

12. Plaintiff denies the allegations in paragraph 12.

13. Plaintiff denies the allegations in paragraph 13.

COUNT II – DECLARATION OF NON-INFRINGEMENT OF THE ’627 PATENT

14. To the extent a response is required to paragraph 14 of the Counterclaims, denied.

15. Plaintiff admits a judicial controversy has arisen concerning Defendants’ 

infringement of the patent-in-suit. Otherwise, denied.

16. Plaintiff denies the allegations in paragraph 16.

17. Plaintiff denies the allegations in paragraph 17.

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PLAINTIFF’S ANSWER TO DEFENDANTS’ COUNTERCLAIMS PAGE 3

18. Plaintiff denies the allegations in paragraph 18.

19. Plaintiff denies the allegations in paragraph 19.

JURY DEMAND

Plaintiff admits this paragraph contains a demand for jury trial to which no response is 

required.

PRAYER FOR RELIEF

Plaintiff denies any factual assertions in the Request for Relief and further denies that 

Defendants are entitled to any of the relief sought in the Request for Relief. 

All allegations in Defendants’ counterclaims that are not specifically admitted herein are 

denied.

Dated: November 3, 2020 Respectfully submitted,

/s/ Ryan S. Loveless

James L. Etheridge

Texas State Bar No. 24059147

Ryan S. Loveless

Texas State Bar No. 24036997

Brett A. Mangrum

Texas State Bar No. 24065671

Travis Lee Richins

Texas State Bar No. 24061296

ETHERIDGE LAW GROUP, PLLC

2600 E. Southlake Blvd., Suite 120 / 324

Southlake, Texas 76092

Telephone: (817) 470-7249

Facsimile: (817) 887-5950

Jim@EtheridgeLaw.com

Ryan@EtheridgeLaw.com

Brett@EtheridgeLaw.com

Travis@EtheridgeLaw.com

ATTORNEYS FOR PLAINTIFF

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PLAINTIFF’S ANSWER TO DEFENDANTS’ COUNTERCLAIMS PAGE 4

CERTIFICATE OF SERVICE

I certify that on November 3, 2020 the foregoing document was served upon all counsel of 

record via the court’s electronic filing system in accordance with the Federal Rules of Civil 

Procedure.

/s/ Ryan S. Loveless

Ryan S. Loveless

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