UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION 

BARCO, INC. and BARCO NV, 

Plaintiffs, 

v. 

YEALINK (USA) NETWORK TECHNOLOGY 

CO., LTD., and YEALINK NETWORK 

TECHNOLOGY CO., LTD., 

Defendants. 

Case No. 2:23-cv-00521-JRG-RSP 

JURY TRIAL DEMANDED 

DEFENDANTS’ SECOND AMENDED ANSWER AND AFFIRMATIVE DEFENSES 

Defendants Yealink (USA) Network Technology Co., Ltd. and Yealink Network 

Technology Co., Ltd. (together, “Defendants” or “Yealink”) hereby provide their second amended 

answer (“SAC”) to Plaintiffs’ Complaint for Patent Infringement (“Complaint”). 

NATURE OF THE ACTION 

1. Yealink admits Paragraph 1 lists U.S. Patent Nos. 10,762,002, 10,795,832, 

10,904,103, 11,258,676, 11,403,237, and 11,422,951 (the “Asserted Patents”). Yealink is without 

knowledge or information sufficient as to the truth of the remaining allegations and denies them. 

2. Yealink does not dispute that its A20-020-TEAMS Video Bar and WPP30 

Presentation Pod products, when and only when used together in the same system, infringed certain 

claims of the Asserted Patents. Yealink avers that as of April 2024, Yealink has already recalled 

its WPP30 Presentation Pod products in the U.S. and has expressly instructed its U.S. distributors 

to cease all sales of Yealink’s WPP30 Presentation Pod products. See https://www.yealink.com/ 

en/product-detail/wireless-presentation-wpp30-eol. Yealink denies its A20-020-TEAMS Video 

Bar product by itself infringed any claims and denies the remaining allegations in Paragraph 2. 

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3. Yealink admits it uses distributors in the United States to sell its A20-020-TEAMS 

Video Bar and WPP30 Presentation Pod products. Yealink denies the remaining allegations in 

Paragraph 3. 

PARTIES 

4. Yealink is without knowledge or information sufficient to form a belief as to the 

truth of the allegations in Paragraph 4 of the Complaint and, on that basis, denies each and every 

allegation therein. 

5. Yealink is without knowledge or information sufficient to form a belief as to the 

truth of the allegations in Paragraph 5 of the Complaint and, on that basis, denies each and every 

allegation therein. 

6. Yealink admits that Yealink (USA) Network Technology Co., Ltd. is a whollyowned subsidiary of and Yealink Network Technology Co., Ltd. Yealink denies all other 

allegations in Paragraph 6 of the Complaint. 

7. Yealink admits that Yealink Network Technology Co., Ltd. is a company organized 

under the laws of China and headquartered at 666 Hu’an Road, Huli District, Xiamen, Fujian 

Province, 361006, China. Yealink denies all other allegations in Paragraph 7 of the Complaint. 

8. Yealink admits it maintains a place of business in the United States at Suite 160, 

5445 Legacy Drive, Plano, Texas 75024. The remainder of Paragraph 8 of the Complaint contains 

legal conclusions to which no response is required and, to the extent a response is required, Yealink 

denies the remaining allegations of Paragraph 8. 

9. Yealink denies each and every allegation in Paragraph 9 of the Complaint. 

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JURISDICTION AND VENUE 

10. Paragraph 10 states a legal conclusion to which no response is required. To the 

extent a response is required, Yealink admits that this action purports to be brought under 35 U.S.C. 

§§ 271 et seq. 

11. Paragraph 11 states a legal conclusion to which no response is required. To the 

extent a response is required, Yealink does not dispute that this Court subject matter jurisdiction 

under 28 U.S.C. §§ 1331 and 1338(a). 

12. Paragraph 12 states a legal conclusion to which no response is required. To the 

extent a response is required, Yealink avers it does not, for the purpose of this action only, contest 

personal jurisdiction. Yealink denies any remaining allegations in Paragraph 12 of the Complaint. 

13. Paragraph 13 states a legal conclusion to which no response is required. To the 

extent a response is required, Yealink avers it does not, for the purpose of this action only, contest 

venue. Yealink denies any remaining allegations in Paragraph 13 of the Complaint. 

14. Paragraph 14 states a legal conclusion to which no response is required. To the 

extent a response is required, Yealink avers it does not, for the purpose of this action only, contest 

personal jurisdiction. Yealink denies any remaining allegations in Paragraph 14 of the Complaint. 

15. Paragraph 15 states a legal conclusion to which no response is required. To the 

extent a response is required, Yealink denies each and every allegation in Paragraph 15 of the 

Complaint. 

16. Paragraph 16 states a legal conclusion to which no response is required. To the 

extent a response is required, Yealink denies each and every allegation in Paragraph 16 of the 

Complaint. 

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17. Paragraph 17 states a legal conclusion to which no response is required. To the 

extent a response is required, Yealink avers it does not, for the purpose of this action only, contest 

venue. Yealink denies any remaining allegations in Paragraph 17 of the Complaint. 

18. Paragraph 18 states a legal conclusion to which no response is required. To the 

extent a response is required, Yealink avers it does not, for the purpose of this action only, contest 

personal jurisdiction. Yealink denies any remaining allegations in Paragraph 18 of the Complaint. 

FACTUAL BACKGROUND 

A. The Asserted Patents 

19. Yealink is without knowledge or information sufficient to form a belief as to the 

truth of the allegations in Paragraph 19 of the Complaint and, on that basis, denies each and every 

allegation therein. 

20. Yealink is without knowledge or information sufficient to form a belief as to the 

truth of the allegations in Paragraph 20 of the Complaint and, on that basis, denies each and every 

allegation therein. 

21. Yealink is without knowledge or information sufficient to form a belief as to the 

truth of the allegations in Paragraph 21 of the Complaint and, on that basis, denies each and every 

allegation therein. 

22. Yealink is without knowledge or information sufficient to form a belief as to the 

truth of the allegations in Paragraph 22 of the Complaint and, on that basis, denies each and every 

allegation therein. 

23. Yealink admits that the ’002 Patent is titled “Electronic Tool and Methods With 

Audio For Meetings” and is issued on September 1, 2020. Yealink further admits that the ’237 

Patent is titled “Electronic Tool and Methods With Audio For Meetings” and is issued on August 

2, 2022. 

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24. Yealink denies each and every allegation in Paragraph 24 of the Complaint. 

25. Yealink admits that Paragraph 25 of the Complaint purports to show a side-by-side 

comparison of Yealink’s product and Barco’s device. Yealink specifically denies that Paragraph 

25 accurately describes Yealink’s product and denies all other allegations in Paragraph 25 of the 

Complaint. 

26. Yealink admits that the ’832 Patent is titled “Electronic Tool For Communicating 

Over A Communication Network” and is issued on October 6, 2020. Yealink further admits that 

the ’103 Patent is titled “Electronic Tool and Methods for Meetings” and is issued on January 26, 

2021. 

27. Yealink denies each and every allegation in Paragraph 27 of the Complaint. 

28. Yealink admits that Paragraph 28 of the Complaint purports to show a side-by-side 

comparison of Yealink’s product and Barco’s device. Yealink specifically denies that Paragraph 

28 accurately describes Yealink’s product and denies all other allegations in Paragraph 28 of the 

Complaint. 

29. Yealink admits that the ’676 Patent is titled “Electronic Tool and Methods for 

Meetings” and is issued on February 22, 2022. Yealink further admits that the ’951 Patent is titled 

“Electronic Tool and Methods For Meetings Between Two Users” and is issued on August 23, 

2022. 

30. Yealink denies each and every allegation in Paragraph 30 of the Complaint. 

31. Yealink admits that Paragraph 31 of the Complaint purports to show a side-by-side 

comparison of Yealink’s product and Barco’s device. Yealink specifically denies that Paragraph 

31 accurately describes Yealink’s product and denies all other allegations in Paragraph 31 of the 

Complaint. 

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32. Yealink is without knowledge or information sufficient to form a belief as to the 

truth of the allegations in Paragraph 32 of the Complaint and, on that basis, denies each and every 

allegation therein. 

B. Yealink’s Products 

33. Yealink admits that it sells and imports certain wireless presentation tools to 

resellers, distributors, and consumers in the United States, including in Texas. Yealink denies all 

other allegations in Paragraph 33 of the Complaint. 

34. Yealink denies each and every allegation in Paragraph 34 of the Complaint. 

35. Paragraph 35 states a legal conclusion to which no response is required. To the 

extent a response is required, Yealink denies the allegations in Paragraph 35 of the Complaint.

C. Yealink’s Purported Refusal to Cease Infringement of Barco’s Patents 

36. Yealink admits that it received a letter from Barco in May 2023 regarding alleged 

infringement of certain patents. Yealink denies all remaining allegations in Paragraph 36 of the 

Complaint. 

37. Yealink admits that in Barco’s May 2023 letter to Yealink, Barco identified 

Yealink’s A20-020-TEAMS Video Bar and WPP30 Presentation Pod as allegedly infringing the 

’002, ’832, and ’951 Patents. The rest of Paragraph 37 contains legal conclusions to which no 

response is required and thus, Yealink denies the remaining allegations in Paragraph 37 of the 

Complaint. 

38. Yealink admits that on August 24, 2023, it received a letter from Barco, which 

identified Yealink’s A20-020-TEAMS Video Bar and WPP30 Presentation Pod as allegedly 

infringing the ’002, ’832, ’951, ’103, ’237 Patents. The rest of Paragraph 38 contains legal 

conclusions to which no response is required and thus, Yealink denies the remaining allegations 

in Paragraph 38 of the Complaint. 

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39. Yealink denies each and every allegation in Paragraph 39 of the Complaint. 

Yealink avers that as of April 2024, Yealink has already recalled its WPP30 Presentation Pod 

products in the U.S. and has expressly instructed its U.S. distributors to cease all sales of Yealink’s 

WPP30 Presentation Pod products. See https://www.yealink.com/en/product-detail/wirelesspresentation-wpp30-eol. 

COUNT I—ALLEGED INFRINGEMENT OF THE ’002 PATENT 

40. Paragraph 40 does not contain any allegations of facts, and, therefore, no answer is 

required. Yealink incorporates by reference its responses in Paragraphs 1 through 39 as though 

fully set forth herein. 

41. Yealink admits that its WPP30 Presentation Pod, when used with a connected 

device, infringed claim 11 of the ’002 Patent. Yealink avers that as of April 2024, Yealink has 

already recalled its WPP30 Presentation Pod products in the U.S. and has expressly instructed its 

U.S. distributors to cease all sales of Yealink’s WPP30 Presentation Pod products. See 

https://www.yealink.com/en/product-detail/wireless-presentation-wpp30-eol. Yealink denies all 

other allegations in Paragraph 41 of the Complaint. 

42. Paragraph 42 states legal conclusions to which no response is required. To the 

extent a response is required, Yealink avers that it does not dispute its WPP30 Presentation Pod, 

when used with a connected device, infringed claim 11 of the ’002 Patent. Yealink denies the 

remaining allegations in Paragraph 42 of the Complaint. 

43. Yealink denies each and every allegation in Paragraph 43 of the Complaint. 

44. Yealink denies each and every allegation in Paragraph 44 of the Complaint. Yealink 

avers that as of April 2024, Yealink has already recalled its WPP30 Presentation Pod products in 

the U.S. and has expressly instructed its U.S. distributors to cease all sales of Yealink’s WPP30 

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Presentation Pod products. See https://www.yealink.com/en/product-detail/wireless-presentationwpp30-eol. 

45. Paragraph 45 states legal conclusions to which no response is required. To the 

extent a response is required, Yealink avers that it does not dispute its WPP30 Presentation Pod, 

when used with a connected device, infringed claim 11 of the ’002 Patent. Yealink avers that as of 

April 2024, Yealink has already recalled its WPP30 Presentation Pod products in the U.S. and has 

expressly instructed its U.S. distributors to cease all sales of Yealink’s WPP30 Presentation Pod 

products. See https://www.yealink.com/en/product-detail/wireless-presentation-wpp30-eol. 

Yealink denies the remaining allegations in Paragraph 45 of the Complaint. 

46. Paragraph 46 states legal conclusions to which no response is required. To the 

extent a response is required, Yealink avers that it does not dispute its WPP30 Presentation Pod, 

when used with a connected device, infringed claim 11 of the ’002 Patent. Yealink denies the 

remaining allegations in Paragraph 46 of the Complaint. 

47. Yealink denies each and every allegation in Paragraph 47 of the Complaint. 

48. Yealink denies each and every allegation in Paragraph 48 of the Complaint. 

Yealink avers that as of April 2024, Yealink has already recalled its WPP30 Presentation Pod 

products in the U.S. and has expressly instructed its U.S. distributors to cease all sales of Yealink’s 

WPP30 Presentation Pod products. See https://www.yealink.com/en/product-detail/wirelesspresentation-wpp30-eol. 

49. Yealink denies each and every allegation in Paragraph 49 of the Complaint. 

COUNT II—ALLEGED INFRINGEMENT OF THE ’832 PATENT 

50. Paragraph 50 does not contain any allegations of facts, and, therefore, no answer is 

required. Yealink incorporates by reference its responses in Paragraphs 1 through 49 as though 

fully set forth herein. 

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51. Yealink admits that its WPP30 Presentation Pod infringed claim 1 of the ’832 

Patent. Yealink avers that as of April 2024, Yealink has already recalled its WPP30 Presentation 

Pod products in the U.S. and has expressly instructed its U.S. distributors to cease all sales of 

Yealink’s WPP30 Presentation Pod products. See https://www.yealink.com/en/productdetail/wireless-presentation-wpp30-eol. Yealink denies all other allegations in Paragraph 41 of the 

Complaint. 

52. Paragraph 52 states legal conclusions to which no response is required. To the 

extent a response is required, Yealink avers that it does not dispute its WPP30 Presentation Pod 

infringed claim 1 of the ’832 Patent. Yealink denies the remaining allegations in Paragraph 42 of 

the Complaint. 

53. Yealink denies each and every allegation in Paragraph 53 of the Complaint. 

54. Yealink denies each and every allegation in Paragraph 54 of the Complaint. Yealink 

avers that as of April 2024, Yealink has already recalled its WPP30 Presentation Pod products in 

the U.S. and has expressly instructed its U.S. distributors to cease all sales of Yealink’s WPP30 

Presentation Pod products. See https://www.yealink.com/en/product-detail/wireless-presentationwpp30-eol. 

55. Paragraph 55 states legal conclusions to which no response is required. To the 

extent a response is required, Yealink avers that it does not dispute its WPP30 Presentation Pod 

infringed claim 1 of the ’832 Patent. Yealink avers that as of April 2024, Yealink has already 

recalled its WPP30 Presentation Pod products in the U.S. and has expressly instructed its U.S. 

distributors to cease all sales of Yealink’s WPP30 Presentation Pod products. See 

https://www.yealink.com/en/product-detail/wireless-presentation-wpp30-eol. Yealink denies the 

remaining allegations in Paragraph 55 of the Complaint. 

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56. Paragraph 56 states legal conclusions to which no response is required. To the 

extent a response is required, Yealink avers that it does not dispute its WPP30 Presentation Pod 

infringed claim 1 of the ’832 Patent. Yealink denies the remaining allegations in Paragraph 56 of 

the Complaint. 

57. Yealink denies each and every allegation in Paragraph 57 of the Complaint. 

58. Yealink denies each and every allegation in Paragraph 58 of the Complaint. Yealink 

avers that as of April 2024, Yealink has already recalled its WPP30 Presentation Pod products in 

the U.S. and has expressly instructed its U.S. distributors to cease all sales of Yealink’s WPP30 

Presentation Pod products. See https://www.yealink.com/en/product-detail/wireless-presentationwpp30-eol. 

59. Yealink denies each and every allegation in Paragraph 59 of the Complaint. 

COUNT III—ALLEGED INFRINGEMENT OF THE ’103 PATENT 

60. Paragraph 60 does not contain any allegations of facts, and, therefore, no answer is 

required. Yealink incorporates by reference its responses in Paragraphs 1 through 59 as though 

fully set forth herein. 

61. Yealink admits that its WPP30 Presentation Pod infringed claim 1 of the ’103 

Patent. Yealink avers that as of April 2024, Yealink has already recalled its WPP30 Presentation 

Pod products in the U.S. and has expressly instructed its U.S. distributors to cease all sales of 

Yealink’s WPP30 Presentation Pod products. See https://www.yealink.com/en/productdetail/wireless-presentation-wpp30-eol. Yealink denies all other allegations in Paragraph 61 of the 

Complaint. 

62. Paragraph 62 states legal conclusions to which no response is required. To the 

extent a response is required, Yealink avers that it does not dispute its WPP30 Presentation Pod 

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infringed claim 1 of the ’103 Patent. Yealink denies the remaining allegations in Paragraph 62 of 

the Complaint. 

63. Yealink denies each and every allegation in Paragraph 63 of the Complaint. 

64. Yealink denies each and every allegation in Paragraph 64 of the Complaint. Yealink 

avers that as of April 2024, Yealink has already recalled its WPP30 Presentation Pod products in 

the U.S. and has expressly instructed its U.S. distributors to cease all sales of Yealink’s WPP30 

Presentation Pod products. See https://www.yealink.com/en/product-detail/wireless-presentationwpp30-eol. 

65. Paragraph 65 states legal conclusions to which no response is required. To the 

extent a response is required, Yealink avers that it does not dispute its WPP30 Presentation Pod 

infringed claim 1 of the ’103 Patent. Yealink avers that as of April 2024, Yealink has already 

recalled its WPP30 Presentation Pod products in the U.S. and has expressly instructed its U.S. 

distributors to cease all sales of Yealink’s WPP30 Presentation Pod products. See 

https://www.yealink.com/en/product-detail/wireless-presentation-wpp30-eol. Yealink denies the 

remaining allegations in Paragraph 65 of the Complaint. 

66. Paragraph 66 states legal conclusions to which no response is required. To the 

extent a response is required, Yealink avers that it does not dispute its WPP30 Presentation Pod 

infringed claim 1 of the ’103 Patent. Yealink denies the remaining allegations in Paragraph 66 of 

the Complaint. 

67. Yealink denies each and every allegation in Paragraph 67 of the Complaint. 

68. Yealink denies each and every allegation in Paragraph 68 of the Complaint. Yealink 

avers that as of April 2024, Yealink has already recalled its WPP30 Presentation Pod products in 

the U.S. and has expressly instructed its U.S. distributors to cease all sales of Yealink’s WPP30 

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Presentation Pod products. See https://www.yealink.com/en/product-detail/wireless-presentationwpp30-eol. 

69. Yealink denies each and every allegation in Paragraph 69 of the Complaint. 

COUNT IV—ALLEGED INFRINGEMENT OF THE ’676 PATENT 

70. Paragraph 70 does not contain any allegations of facts, and, therefore, no answer is 

required. Yealink incorporates by reference its responses in Paragraphs 1 through 69 as though 

fully set forth herein. 

71. Yealink admits that its A20-020-TEAMS Video Bar and WPP30 Presentation Pod 

products, when and only when used together in the same system, infringed claim 1 of the ’676 

Patent. Yealink avers that as of April 2024, Yealink has already recalled its WPP30 Presentation 

Pod products in the U.S. and has expressly instructed its U.S. distributors to cease all sales of 

Yealink’s WPP30 Presentation Pod products. See https://www.yealink.com/en/productdetail/wireless-presentation-wpp30-eol. Yealink specifically denies its A20-020-TEAMS Video 

Bar product by itself infringed any claims of the ’676 Patent. Yealink denies all other allegations 

in Paragraph 71 of the Complaint. 

72. Paragraph 72 states legal conclusions to which no response is required. To the 

extent a response is required, Yealink avers that it does not dispute its A20-020-TEAMS Video 

Bar and WPP30 Presentation Pod products, when and only when used together in the same system, 

infringed claim 1 of the ’676 Patent. Yealink specifically denies its A20-020-TEAMS Video Bar 

product by itself infringed any claims of the ’676 Patent. Yealink denies the remaining allegations 

in Paragraph 72 of the Complaint. 

73. Yealink denies each and every allegation in Paragraph 73 of the Complaint. 

74. Yealink denies each and every allegation in Paragraph 74 of the Complaint. Yealink 

avers that as of April 2024, Yealink has already recalled its WPP30 Presentation Pod products in 

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the U.S. and has expressly instructed its U.S. distributors to cease all sales of Yealink’s WPP30 

Presentation Pod products. See https://www.yealink.com/en/product-detail/wireless-presentationwpp30-eol. 

75. Paragraph 75 states legal conclusions to which no response is required. To the 

extent a response is required, Yealink avers that it does not dispute its A20-020-TEAMS Video 

Bar and WPP30 Presentation Pod products, when and only when used together in the same system, 

infringed claim 1 of the ’676 Patent. Yealink avers that as of April 2024, Yealink has already 

recalled its WPP30 Presentation Pod products in the U.S. and has expressly instructed its U.S. 

distributors to cease all sales of Yealink’s WPP30 Presentation Pod products. See https:// 

www.yealink.com/en/product-detail/wireless-presentation-wpp30-eol. Yealink specifically denies 

its A20-020-TEAMS Video Bar product by itself infringed any claims of the ’676 Patent. Yealink 

denies the remaining allegations in Paragraph 75 of the Complaint. 

76. Paragraph 76 states legal conclusions to which no response is required. To the 

extent a response is required, Yealink avers that it does not dispute its A20-020-TEAMS Video 

Bar and WPP30 Presentation Pod products, when and only when used together in the same system, 

infringed claim 1 of the ’676 Patent. Yealink specifically denies its A20-020-TEAMS Video Bar 

product by itself infringed any claims of the ’676 Patent. Yealink denies the remaining allegations 

in Paragraph 76 of the Complaint. 

77. Yealink denies each and every allegation in Paragraph 77 of the Complaint. 

78. Yealink denies each and every allegation in Paragraph 78 of the Complaint. Yealink 

avers that as of April 2024, Yealink has already recalled its WPP30 Presentation Pod products in 

the U.S. and has expressly instructed its U.S. distributors to cease all sales of Yealink’s WPP30 

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Presentation Pod products. See https://www.yealink.com/en/product-detail/wireless-presentationwpp30-eol. 

79. Yealink denies each and every allegation in Paragraph 79 of the Complaint. 

COUNT V—ALLEGED INFRINGEMENT OF THE ’237 PATENT 

80. Paragraph 80 does not contain any allegations of facts, and, therefore, no answer is 

required. Yealink incorporates by reference its responses in Paragraphs 1 through 79 as though 

fully set forth herein. 

81. Yealink admits that its WPP30 Presentation Pod products, when used with a 

connected device, infringed claim 1 of the ’237 Patent. Yealink avers that as of April 2024, Yealink 

has already recalled its WPP30 Presentation Pod products in the U.S. and has expressly instructed 

its U.S. distributors to cease all sales of Yealink’s WPP30 Presentation Pod products. See 

https://www.yealink.com/en/product-detail/wireless-presentation-wpp30-eol. Yealink denies all 

other allegations in Paragraph 81 of the Complaint. 

82. Paragraph 82 states legal conclusions to which no response is required. To the 

extent a response is required, Yealink avers that it does not dispute its WPP30 Presentation Pod 

products, when used with a connected device, infringed claim 1 of the ’237 Patent. Yealink denies 

the remaining allegations in Paragraph 82 of the Complaint. 

83. Yealink denies each and every allegation in Paragraph 83 of the Complaint. 

84. Yealink denies each and every allegation in Paragraph 84 of the Complaint. Yealink 

avers that as of April 2024, Yealink has already recalled its WPP30 Presentation Pod products in 

the U.S. and has expressly instructed its U.S. distributors to cease all sales of Yealink’s WPP30 

Presentation Pod products. See https://www.yealink.com/en/product-detail/wireless-presentationwpp30-eol. 

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85. Paragraph 85 states legal conclusions to which no response is required. To the 

extent a response is required, Yealink avers that it does not dispute its WPP30 Presentation Pod 

products, when used with a connected device, infringed claim 1 of the ’237 Patent. Yealink avers 

that as of April 2024, Yealink has already recalled its WPP30 Presentation Pod products in the 

U.S. and has expressly instructed its U.S. distributors to cease all sales of Yealink’s WPP30 

Presentation Pod products. See https://www.yealink.com/en/product-detail/wireless-presentationwpp30-eol. Yealink denies the remaining allegations in Paragraph 85 of the Complaint. 

86. Paragraph 86 states legal conclusions to which no response is required. To the 

extent a response is required, Yealink avers that it does not dispute its WPP30 Presentation Pod 

products, when used with a connected device, infringed claim 1 of the ’237 Patent. Yealink denies 

the remaining allegations in Paragraph 86 of the Complaint. 

87. Yealink denies each and every allegation in Paragraph 87 of the Complaint. 

88. Yealink denies each and every allegation in Paragraph 88 of the Complaint. Yealink 

avers that as of April 2024, Yealink has already recalled its WPP30 Presentation Pod products in 

the U.S. and has expressly instructed its U.S. distributors to cease all sales of Yealink’s WPP30 

Presentation Pod products. See https://www.yealink.com/en/product-detail/wireless-presentationwpp30-eol. 

89. Yealink denies each and every allegation in Paragraph 89 of the Complaint. 

COUNT VI—ALLEGED INFRINGEMENT OF THE ’951 PATENT 

90. Paragraph 90 does not contain any allegations of facts, and, therefore, no answer is 

required. Yealink incorporates by reference its responses in Paragraphs 1 through 89 as though 

fully set forth herein. 

91. Yealink admits that its A20-020-TEAMS Video Bar and WPP30 Presentation Pod 

products, when and only when used together in the same system, infringed claim 1 of the ’951 

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Patent. Yealink avers that as of April 2024, Yealink has already recalled its WPP30 Presentation 

Pod products in the U.S. and has expressly instructed its U.S. distributors to cease all sales of 

Yealink’s WPP30 Presentation Pod products. See https://www.yealink.com/en/productdetail/wireless-presentation-wpp30-eol. Yealink specifically denies its A20-020-TEAMS Video 

Bar product by itself infringed any claims of the ’951 Patent. Yealink denies all other allegations 

in Paragraph 91 of the Complaint. 

92. Paragraph 92 states legal conclusions to which no response is required. To the 

extent a response is required, Yealink avers that it does not dispute its A20-020-TEAMS Video 

Bar and WPP30 Presentation Pod products, when and only when used together in the same system, 

infringed claim 1 of the ’951 Patent. Yealink specifically denies its A20-020-TEAMS Video Bar 

product by itself infringed any claims of the ’951 Patent. Yealink denies the remaining allegations 

in Paragraph 92 of the Complaint. 

93. Yealink denies each and every allegation in Paragraph 93 of the Complaint. 

94. Yealink denies each and every allegation in Paragraph 94 of the Complaint. Yealink 

avers that as of April 2024, Yealink has already recalled its WPP30 Presentation Pod products in 

the U.S. and has expressly instructed its U.S. distributors to cease all sales of Yealink’s WPP30 

Presentation Pod products. See https://www.yealink.com/en/product-detail/wireless-presentationwpp30-eol. 

95. Paragraph 95 states legal conclusions to which no response is required. To the 

extent a response is required, Yealink avers that it does not dispute its A20-020-TEAMS Video 

Bar and WPP30 Presentation Pod products, when and only when used together in the same system, 

infringed claim 1 of the ’951 Patent. Yealink avers that as of April 2024, Yealink has already 

recalled its WPP30 Presentation Pod products in the U.S. and has expressly instructed its U.S. 

Case 2:23-cv-00521-JRG-RSP Document 47 Filed 09/20/24 Page 16 of 20 PageID #: 433
17 

distributors to cease all sales of Yealink’s WPP30 Presentation Pod products. See https:// 

www.yealink.com/en/product-detail/wireless-presentation-wpp30-eol. Yealink specifically denies 

its A20-020-TEAMS Video Bar product by itself infringed any claims of the ’951 Patent. Yealink 

denies the remaining allegations in Paragraph 95 of the Complaint. 

96. Paragraph 96 states legal conclusions to which no response is required. To the 

extent a response is required, Yealink avers that it does not dispute its A20-020-TEAMS Video 

Bar and WPP30 Presentation Pod products, when and only when used together in the same system, 

infringed claim 1 of the ’951 Patent. Yealink specifically denies its A20-020-TEAMS Video Bar 

product by itself infringed any claims of the ’951 Patent. Yealink denies the remaining allegations 

in Paragraph 96 of the Complaint. 

97. Yealink denies each and every allegation in Paragraph 97 of the Complaint. 

98. Yealink denies each and every allegation in Paragraph 98 of the Complaint. Yealink 

avers that as of April 2024, Yealink has already recalled its WPP30 Presentation Pod products in 

the U.S. and has expressly instructed its U.S. distributors to cease all sales of Yealink’s WPP30 

Presentation Pod products. See https://www.yealink.com/en/product-detail/wireless-presentationwpp30-eol. 

99. Yealink denies each and every allegation in Paragraph 99 of the Complaint.

RESPONSE TO PRAYER FOR RELIEF 

To the extent that the Prayer for Relief section of the Complaint is deemed to allege any 

facts or entitlements to the relief requested, Yealink denies each and every allegation. Specifically, 

Yealink denies that Barco is entitled to any relief whatsoever. 

ADDITIONAL AND AFFIRMATIVE DEFENSES 

Yealink asserts the following additional and affirmative defenses without assuming any 

burden of proof when such burden would otherwise be on Barco. Yealink repeats and incorporates 

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18 

by reference each of its answers in paragraphs 1 through 99 and the Response to Prayer for Relief 

as set forth above with each of the following defenses as if fully set forth herein. Further, Yealink 

specifically reserves all rights to assert additional defenses and affirmative defenses as additional 

information becomes available. 

FIRST DEFENSE 

The claims of the ’002, ’832, ’103, ’676, ’237, ’951 Patents are invalid for failure to meet 

the requirements of 35 U.S.C. § 112 and/or 35 U.S.C. § 101. 

SECOND DEFENSE 

Barco’s claims against Yealink are barred, in whole or in part, by 35 U.S.C. § 287. 

THIRD DEFENSE 

Barco is precluded from recovering costs under 35 U.S.C. § 288. 

FOURTH DEFENSE 

Barco is not entitled to any injunctive relief because, among other reasons, any alleged 

injury is not immediate or irreparable, and Barco has an adequate remedy at law for any alleged 

injury. 

Case 2:23-cv-00521-JRG-RSP Document 47 Filed 09/20/24 Page 18 of 20 PageID #: 435
19 

Dated: September 20, 2024 Respectfully submitted, 

DENTONS US LLP 

/s/ Victor C. Johnson 

Victor C. Johnson 

Texas Bar No. 24029640 

Forrest D. Gothia 

Texas Bar No. 24125250 

100 Crescent Court, Suite 900 

Dallas, Texas 75201 

(214) 259-1876 

Email: victor.johnson@dentons.com 

(214) 259-1887 

Email: forrest.gothia@dentons.com 

 

Stephen Yang (Pro Hac Vice granted) 

New York State Bar No. 5123492 

1221 Avenue of the Americas 

New York, New York 10020-1089 

(212) 398-4890 

Email: stephen.yang@dentons.com 

Timothy C. Bickham (Pro Hac Vice granted) 

DC State Bar No. 45614 

Mark Consilvio (Pro Hac Vice granted) 

Maryland State Bar No. 1312170173 

1900 K Street, NW 

Washington, DC 20006-1102 

(202) 408-6390 

Email: timothy.bickham@dentons.com 

(202) 408-3938 

Email: mark.consilvio@dentons.com 

Attorneys for Defendants Yealink (USA) 

Network Technology Co., Ltd. and Yealink 

Network Technology Co., Ltd. 

Case 2:23-cv-00521-JRG-RSP Document 47 Filed 09/20/24 Page 19 of 20 PageID #: 436
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CERTIFICATE OF SERVICE 

I certify that on September 20, 2024, a true and correct copy of the foregoing document 

was electronically filed and served on all counsel of record using the Court’s CM/ECF system, in 

accordance with the Federal Rules of Civil Procedure and Local Rule 5.1. 

/s/ Victor C. Johnson 

Victor C. Johnson 

Case 2:23-cv-00521-JRG-RSP Document 47 Filed 09/20/24 Page 20 of 20 PageID #: 437