22-04-04 ITC-1300 Apple Answer To Complaint

UNITED STATES INTERNATIONAL TRADE COMMISSION
WASHINGTON, D.C.
Before the Honorable MaryJoan McNamara

Administrative Law Judge
In the Matter of
CERTAIN MOBILE PHONES, TABLET

COMPUTERS, SMART WATCHES, Inv. No. 337-TA-1300
SMART SPEAKERS, AND DIGITAL
MEDIA PLAYERS, AND PRODUCTS
CONTAINING SAME
RESPONDENT APPLE INC.’S RESPONSE TO THE COMPLAINT OF

ERICSSON INC. AND TELEFONAKTIEBOLAGET LM ERICSSON UNDER
SECTION 337 OF THE TARIFF ACT OF 1930, AS AMENDED,
AND NOTICE OF INVESTIGATION
RESPONDENT COUNSEL FOR APPLE INC.
Apple Inc. Benjamin C. Elacqua

Fish & Richardson P.C.
One Apple Park Way 1221 McKinney Street, Suite 2800
Cupertino, CA 95014 Houston, TX 77010
Tel: 408-996-1010 Telephone: (713) 654-5300
Facsimile: (713) 652-0109
Betty Chen
500 Arguello Street
Suite 500
Redwood, CA 94063
Telephone: (650) 839-5070
Facsimile: (650) 839-5071
Ruffin B. Cordell
Richard A. Sterba
1000 Maine Avenue, S.W., Suite 1000
Washington, D.C. 20024
Telephone: (202) 783-5070
Facsimile: (202) 783-2331
Inv. No. 337-TA-1300

Apple Inc.’s Response to Complaint and Notice
Aamir Kazi
Benjamin Thompson
Jacqueline Tio
Katherine Reardon
1180 Peachtree St SE, Suite 2100
Atlanta, GA 30309
Telephone: (404) 892-5005
Facsimile: (404) 892-5002
Andrew Pearson
Whitney Reichel
One Marina Park Drive
Boston, MA 02210
Telephone: (617) 542-5070
Inv. No. 337-TA-1300

PREAMBLE
Pursuant to 19 C.F.R. § 210.13, Respondent Apple Inc. (“Apple” or “Respondent”) by
and through its attorneys, hereby responds to the Complaint Under Section 337 of the Tariff Act
of 1930 as Amended (the “Complaint”), filed by Ericsson Inc. and Telefonaktiebolaget LM
Ericsson (“Ericsson” or “Complainants”) on January 18, 2022, and to the Notice of Institution of
Investigation (the “Notice”) published in the Federal Register on February 24, 2022 (87 Fed.
Reg. 10385).
Apple denies that it has engaged in acts of unfair competition in violation of Section 337
by importing, selling for importation, and/or selling after importation into the United States any
product that infringes, literally and/or under the doctrine of equivalents, directly, indirectly, by
contribution and/or by inducement, any valid Asserted Claim of U.S. Patent Nos. 7,151,430 (“the
’430 patent”); 9,509,273 (“the ’273 patent”); 9,853,621 (“the ’621 patent”); 7,957,770 (“the ’770
patent”); and 9,705,400 (“the ’400 patent”) (collectively, “the Asserted Patents”). Apple denies
that the Asserted Claims of the Asserted Patents are valid and enforceable. Except as
specifically admitted herein, Apple denies all of the allegations of the Complaint. To the extent
that any allegations of the Complaint refer to or rely upon information not previously supplied to
Apple, Apple is without information sufficient to admit or deny such allegations, and therefore
denies the same. In responding to the Complaint and the Notice, Apple has understood
“Accused Products” to mean the products accused of infringement in the Complaint. Apple
reserves the right to take further positions and raise additional defenses as may become apparent
as a result of additional information discovered subsequent to filing this Response, or to the
extent Ericsson modifies its Complaint or contentions.
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RESPONSE TO COMPLAINT
In answer to the allegations set forth in the Complaint, Apple responds as follows:
I. INTRODUCTION1
1. To the extent that Paragraph 1 contains conclusions of law, no response is
necessary. Apple denies that it has engaged in unlawful importation into the United States, sale
for importation into the United States, offer for sale for importation into the United States, and/or
sale within the United States after importation of the Accused Products. Apple further denies that
the Accused Products infringe any valid Asserted Claim of the ’430 patent, the ’273 patent, the
’621 patent, the ’770 patent, or the ’400 patent.
necessary. Apple admits that Exhibits 1-5 to the Complaint purport to be certified and uncertified
copies of the Asserted Patents, Exhibits 6-10 to the Complaint purport to be certified and
uncertified copies of the recorded assignments for the Asserted Patents, and Appendices Nos. A-
E to the Complaint purport to be certified and uncertified copies of the prosecution histories of the
Asserted Patents. Apple lacks sufficient knowledge or information to form a belief as to the truth
of any remaining allegations contained in Paragraph 2 and, on that basis, denies them.
3. Apple admits that Apple is the Proposed Respondent in the Complaint. Apple
admits that certain mobile phones, tablet computers, smart watches, smart speakers, and digital
media players are manufactured and assembled overseas, and are sold for importation into the
United States, imported into the United States, or sold within the United States after importation
1
Apple has adopted headings in the Complaint for ease of reference. However, to the extent that
such headings themselves contain factual and legal characterizations, Apple denies such
characterizations.
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by or on behalf of Apple. Apple denies the remaining allegations and characterizations contained
in Paragraph 3.
necessary. Apple lacks sufficient knowledge or information to form a belief as to the truth of the
allegations contained in Paragraph 4 and, on that basis, denies them.
necessary. Apple admits that Ericsson seeks relief in the Complaint, including a permanent
exclusion order, a cease and desist order, and the imposition of a bond during the Presidential
review period. Apple denies that any of its Accused Products infringe any valid and enforceable
Asserted Claim of the Asserted Patents. Apple denies that it has violated Section 337 in any
manner. Apple denies that Ericsson is entitled to any relief whatsoever, including without
limitation, the relief requested in Paragraph 5.
II. COMPLAINANTS
6. Apple admits that Ericsson Inc. and Telefonaktiebolaget LM Ericsson are the
Complainants in this investigation.
7. On information and belief, Apple admits that Ericsson Inc. is a corporation
organized and existing under the laws of the State of Delaware, having its principal place of
business at 6300 Legacy Drive, Plano, Texas 75024.
8. On information and belief, Apple admits that LM Ericsson is a corporation
organized and existing under the laws of the Kingdom of Sweden, having its principal place of
business at Torshamnsgatan 21, Kista, SE-164 83 Stockholm, Sweden. Apple lacks sufficient
knowledge or information to form a belief as to the truth of the remaining allegations contained in
Paragraph 8 and, on that basis, denies them.
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9. Apple lacks sufficient knowledge or information to form a belief as to the truth of
the allegations contained in Paragraph 9 and, on that basis, denies them.
the remaining allegations contained in Paragraph 12 and, on that basis, denies them.
III. PROPOSED RESPONDENT APPLE
13. Apple admits that it is a corporation organized under the laws of the State of
California. Apple admits that its principal place of business is at One Apple Park Way, Cupertino,
CA 95014.
14. Apple admits that it designs, develops, imports, and sells after importation certain
iPhones, iPads, Apple Watches, Apple HomePods, and Apple TVs. Apple admits that certain
iPhones, iPads, Apple Watches, Apple HomePods, and Apple TVs are manufactured on behalf of
Apple. Apple admits that certain Accused Products within the United States are sold through retail
and online stores, direct sales, and third-party resellers. Apple admits that it performs services to
support the sale of certain Accused Products into and within the United States, including marketing
certain Accused Products, developing and distributing software, and certain after-sale services. To
the extent not specifically and expressly admitted, Apple denies all other allegations and
characterizations in Paragraph 14.
IV. THE ACCUSED PRODUCTS AND TECHNOLOGY AT ISSUE
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necessary. Apple admits that Complainants have described the Accused Products as “Apple
mobile phones, tablet computers, smart watches, smart speakers, and digital Media Players, and
products containing same,” pursuant to Commission Rule 210.12(a)(12). Apple admits that
Complainants have further described the Accused Products to “include, but are not limited to, the
Apple iPhone mobile phones, Apple iPad tablet computers, Apple Watch smart watches, Apple
HomePod smart speakers, and Apple TV digital media players.” To the extent not specifically and
expressly admitted, Apple denies all other allegations and characterizations in Paragraph 15.
necessary. Apple denies that the allegations and characterizations contained in Paragraph 16
constitute a complete and accurate description of the ’430, ’273, ’621, ’770, or ’400 patent. Apple
lacks sufficient knowledge or information to form a belief as to the truth of the allegations and
characterizations contained in Paragraph 16 and, on that basis, denies them.
V. THE ASSERTED PATENTS AND NON-TECHNICAL DESCRIPTIONS
A. U.S. Patent 7,151,430
Identification and Ownership of the ’430 Patent
17. Apple admits that the ’430 patent states on its face that it is titled “Method of and
Inductor Layout for Reduced VCO Coupling,” issued on December 19, 2006. Apple admits that
the ’430 patent on its face lists Thomas Mattsson as the inventor. Apple admits that the ’430 patent
states on its face that it issued from Application No. 10/919,130, filed on August 16, 2004. Apple
admits that Exhibit 1 to the Complaint purports to be a copy of the ’430 Patent. Apple lacks
sufficient knowledge or information to form a belief as to the truth of the remaining allegations
contained in Paragraph 17 and, on that basis, denies them.
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necessary. Apple admits that the ’430 patent on its face shows that it has 3 independent claims
and 18 dependent claims. Apple denies that any of its Accused Products infringe any valid and
enforceable Asserted Claim of the ’430 patent. Apple denies that it has violated Section 337 in
any manner. Apple denies that the Asserted Claims of the ’430 patent are valid, enforceable, or
currently in full force and effect until February 2, 2025. Apple admits that Exhibit 1 to the
Complaint purports to be a copy of the ’430 patent. Apple lacks sufficient knowledge or
information to form a belief as to the truth of the remaining allegations and characterizations
necessary. Apple admits that Exhibit 6 to the Complaint is a document that purports to reflect an
assignment of U.S. Patent Application No. 10/919130. Apple lacks knowledge or information
sufficient to form a belief regarding the truth of the remaining statements and allegations in
20. Apple admits that Appendix A purports to be an electronic version of a certified
copy of the prosecution history of the ’430 patent. Apple admits that Appendix F purports to
include electronic copies of technical references identified in the prosecution history of the ’430
patent. To the extent not specifically and expressly admitted, Apple denies all other allegations
and characterizations in Paragraph 20.
Non-Technical Description of the ’430 Patent
constitute a complete and accurate description of the ’430 patent. Apple denies the allegations
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contained in Paragraph 21 as they relate in any way to a proposed construction of any Asserted
Claim of the ’430 patent. Apple further denies that the ’430 patent discloses anything novel,
inventive, or nonobvious. Apple is without knowledge or information sufficient to form a belief
as to the truth of the remaining allegations contained in Paragraph 21 and, on that basis, denies
them.
Foreign Counterparts
necessary. Apple lacks knowledge or information sufficient to form a belief regarding the truth of
the statements and allegations in Paragraph 22 and, on that basis, denies them.
Licenses
24. Apple admits that Confidential Exhibit 23C purports to contain a list of entities with
a current license involving the ’430 patent. Apple lacks knowledge or information sufficient to
form a belief regarding the truth of the remaining statements and allegations in Paragraph 24 and,
on that basis, denies them.
B. U.S. Patent Nos. 9,509,273 and 9,853,621
Identification and Ownership of the ’273 Patent and the ’621 Patent
25. Apple admits that the ’273 patent states on its face that it is titled “Transformer
Filter Arrangement,” issued on November 29, 2016. Apple admits that the ’273 patent on its face
lists Stefan Andersson, Fenghao Mu, and Johan Wernehag as the inventors. Apple admits that the
’273 patent states on its face that it issued from Application No. 14/233,497, filed as Application
No. PCT/SE2012/050729 on June 28, 2012. Apple admits that Exhibit 2 to the Complaint purports
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to be a copy of the ’273 Patent. Apple lacks knowledge or information sufficient to form a belief
regarding the truth of the remaining statements contained in Paragraph 25 and, on that basis, denies
them.
26. Apple admits that the ’621 patent states on its face that it is titled “Transformer
Filter Arrangement,” issued on December 26, 2017. Apple admits that the ’621 patent on its face
lists Stefan Andersson, Fenghao Mu, and Johan Wernehag as the inventors. Apple admits that the
’621 patent states on its face that it issued from Application No. 15/044,466, filed on February 16,
2016, and states on its face that it is a continuation of Application No. 14/233,497, filed as
Application No. PCT/SE2012/050729 on June 28, 2012, now U.S. Patent No. 9,509,273. Apple
admits that Exhibit 3 to the Complaint purports to be a copy of the ’621 patent. Apple lacks
knowledge or information sufficient to form a belief regarding the truth of the remaining
statements contained in Paragraph 26 and, on that basis, denies them.
any manner. Apple admits that Exhibit 2 to the Complaint purports to be a copy of the ’273 Patent.
Apple lacks knowledge or information sufficient to form a belief regarding the truth of the
remaining statements and allegations contained in Paragraph 27 and, on that basis, denies them.
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any manner. Apple admits that Exhibit 3 to the Complaint purports to be a copy of the ’621 Patent.
Apple lacks knowledge or information sufficient to form a belief regarding the truth of the
remaining statements and allegations contained in Paragraph 28 and, on that basis, denies them.
necessary. Apple denies that the Asserted Claims of the ’273 patent are valid, enforceable, or
currently in full force and effect until July 23, 2032.
currently in full force and effect until July 23, 2032.
31. Apple admits that Exhibit 7 to the Complaint is a document that purports to reflect
an assignment of U.S. Application No. 14/233,497, but denies that Exhibit 8 to the Complaint is a
copy of the assignment document for the ’621 patent. Apple lacks knowledge or information
32. Apple admits that Appendix B purports to be an electronic version of a certified
copy of the prosecution history of the ’273 patent, and Appendix C purports to be an electronic
copy of the prosecution history of the ’621 patent, which issued from a continuation application.
Apple admits that Appendix G purports to include electronic copies of technical references
identified in the prosecution history of the ’273 patent, and Appendix H purports to include
electronic copies of technical references identified in the prosecution history of the ’621 patent.
To the extent not specifically and expressly admitted, Apple denies all other allegations and
characterizations in Paragraph 32.
Non-Technical Description of the ’273 Patent and the ’621 Patent
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33. Due Apple denies that the allegations and characterizations contained in Paragraph
33 constitute a complete and accurate description of the ’273 and ’621 patents. Apple denies the
allegations contained in Paragraph 33 as they relate in any way to a proposed construction of any
Asserted Claim of the ’273 patent or any Asserted Claim of the ’621 patent. Apple further denies
that the ’273 and the ’621 patents disclose anything novel, inventive, or nonobvious. Apple is
without knowledge or information sufficient to form a belief as to the truth of the remaining
allegations contained in Paragraph 33 and, on that basis, denies them.
constitute a complete and accurate description of the ’273 and ’621 patents. Apple denies the
allegations contained in Paragraph 34 as they relate in any way to a proposed construction of any
Asserted Claim of the ’273 patent or any Asserted Claim of the ’621 patent. Apple further denies
that the ’273 and ’621 patents disclose anything novel, inventive, or nonobvious. Apple is without
knowledge or information sufficient to form a belief as to the truth of the remaining allegations
Licenses
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a current license involving the ’273 and ’621 patents. Apple lacks knowledge or information
C. U.S. Patent No. 7,957,770
38. Apple admits that the ’770 patent states on its face that it is titled “Mobile
Communication Terminal for Providing Tactile Interface,” issued on June 7, 2011. Apple admits
that the ’770 patent on its face lists Hyunjun An, Ju-Nam Kim, and Min Hak Lee as the inventors.
Apple admits that the ’770 patent states on its face that it issued from Application No. 11/955,300,
filed on December 12, 2007. Apple admits that Exhibit 4 to the Complaint purports to be a copy
of the ’770 Patent. Apple lacks knowledge or information sufficient to form a belief regarding the
truth of the remaining statements contained in Paragraph 38 and, on that basis, denies them.
enforceable Asserted Claims of the ’770 patent. Apple denies that it has violated Section 337 in
any manner. Apple lacks knowledge or information sufficient to form a belief regarding the truth
of the remaining statements and allegations contained in Paragraph 39 and, on that basis, denies
them.
currently in full force and effect until June 16, 2029.
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assignment of U.S. Application No. 11/955,300. Apple lacks knowledge or information sufficient
to form a belief regarding the truth of the remaining statements and allegations in Paragraph 41
and, on that basis, denies them.
42. Apple admits that Appendix D purports to be an electronic version of a certified
copy of the prosecution history of the ’770 patent. Apple admits that Appendix I purports to
include electronic copies of technical references identified in the prosecution history of the ’770
patent. To the extent not specifically and expressly admitted, Apple denies all other allegations
and characterizations in Paragraph 42.
43. Apple denies that the allegations and characterizations contained in Paragraph 43
them.
constitute a complete and accurate description of the’770 patent. Apple denies the allegations
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them.
them.
Licenses
D. U.S. Patent 9,705,400
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49. Apple admits that the ’400 patent states on its face that it is titled “Reconfigurable
Output Stage,” issued July 11, 2017. Apple admits that the ’400 patent on its face lists Philippe
Sirito-Olivier, Patrizia Milazzo, and Angelo Nagari as the inventors. Apple admits that the ’400
patent states on its face that it issued from Application No. 14/889,892, filed on June 2, 2014.
Apple admits that Exhibit 5 to the Complaint purports to be a copy of the ’400 Patent. Apple lacks
knowledge or information sufficient to form a belief regarding the truth of the remaining
statements contained in Paragraph 49 and, on that basis, denies them.
any manner. Apple lacks knowledge or information sufficient to form a belief regarding the truth
of the remaining statements and allegations contained in Paragraph 50 and, on that basis, denies
them.
currently in full force and effect until June 26, 2034.
assignment of U.S. Application No. 14/889,892. Apple lacks knowledge or information sufficient
to form a belief regarding the truth of the remaining statements and allegations in Paragraph 52
and, on that basis, denies them.
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53. Apple admits that Appendix E purports to be an electronic version of a copy of the
prosecution history of the ’400 patent. Apple admits that Appendix J purports to include electronic
copies of technical references identified in the prosecution history of the ’400 patent. To the extent
not specifically and expressly admitted, Apple denies all other allegations and characterizations in
Paragraph 53.
them.
them.
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Licenses
VI. SPECIFIC INSTANCES OF UNFAIR IMPORTATION AND SALE
59. Apple admits that certain Accused Products are manufactured and assembled at
facilities outside the United States. Apple admits that certain Accused Products are sold for
importation into the United States, imported into the United States, and/or sold within the United
States after importation by or on behalf of Apple. To the extent not specifically and expressly
admitted, Apple denies all other allegations and characterizations in Paragraph 59.
60. Apple admits that certain models of the Accused Products are sold in the United
States. Apple admits that it has over 270 retail stores in the United States where certain models of
the Accused Products may be purchased. To the extent not specifically and expressly admitted,
Apple denies all other allegations and characterizations in Paragraph 60.
61. Apple admits that certain Apple iPhones are assembled in China, then imported and
sold within the United States by or on behalf of Apple. Apple admits that Exhibit 26 to the
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Complaint purports to be a copy of purchasing documents and photographs of an Apple iPhone 13
Pro. Apple admits that Exhibit 26 to the Complaint purports to show that an iPhone 13 Pro was
purchased from an Apple Store in Georgetown, Washington, D.C., on January 15, 2022, and was
assembled in China. To the extent not specifically and expressly admitted, Apple denies all other
allegations and characterizations in Paragraph 61.
62. Apple admits that certain Apple iPads are assembled in China, then imported and
Complaint purports to be a copy of purchasing documents and photographs of an Apple iPad Pro
Wi-Fi + Cellular. Apple admits that Exhibit 27 to the Complaint purports to show that an iPad Pro
Wi-Fi + Cellular was purchased from an Apple Store in Georgetown, Washington, D.C., on
January 15, 2022, and was assembled in China. To the extent not specifically and expressly
63. Apple admits that certain Apple Watches are assembled in Vietnam, then imported
and sold within the United States by or on behalf of Apple. Apple admits that Exhibit 28 to the
Complaint purports to be a copy of purchasing documents and photographs of an Apple Watch
Series 7. Apple admits that Exhibit 28 to the Complaint purports to show that an Apple Watch
Series 7 was purchased from a Target Store in Washington, D.C., on January 15, 2022, and was
made in Vietnam. To the extent not specifically and expressly admitted, Apple denies all other
64. Apple admits that certain Apple HomePods are assembled in Vietnam, then
imported and sold within the United States by or on behalf of Apple. Apple admits that Exhibit
29 to the Complaint purports to be a copy of purchasing documents and photographs of an Apple
HomePod mini. Apple admits that Exhibit 29 to the Complaint purports to show that a HomePod
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mini was purchased from an Apple Store in Georgetown, Washington, D.C., on January 15, 2022,
and was made in Vietnam. To the extent not specifically and expressly admitted, Apple denies all
other allegations and characterizations in Paragraph 64.
65. Apple admits that certain Apple TVs are assembled in China, then imported and
Complaint purports to be a copy of purchasing documents and photographs of an Apple TV 4K.
Apple admits that Exhibit 30 to the Complaint purports to show that an Apple TV 4K was
purchased from an Apple Store in Georgetown, Washington, D.C., on January 15, 2022, and was
assembled in China. To the extent not specifically and expressly admitted, Apple denies all other
the statements and allegations in Paragraph 66 and, on that basis, denies them. Apple denies that
any of the Accused Products infringe any valid and enforceable Asserted Claim of the Asserted
Patents, or that Apple has violated Section 337 in any manner.
VII. ALLEGED UNLAWFUL AND UNFAIR ACTS OF RESPONDENT – PATENT

INFRINGEMENT
67. Apple denies each and every allegation in Paragraph 67.
A. Alleged Infringement of the ’430 Patent
71. Apple admits that Ericsson filed a district court action against Apple in the United
States District Court for the Eastern District of Texas on February 26, 2015, asserting patent
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infringement. Apple admits that Ericsson provided a copy of this Complaint to Apple in advance
of filing. Apple admits that this Complaint is accompanied by a claim chart where Ericsson
purports to allege that the Accused Products infringe an Asserted Claim of the ’430 patent. Apple
denies each and every remaining allegation of Paragraph 71.
72. Apple admits that Exhibit 11 to this Complaint purports to be a claim chart of the
’430 patent. Apple denies that any of the Accused Products infringe any valid and enforceable
Asserted Claim of the ’430 patent. Apple denies each and every remaining allegation of Paragraph
72.
B. Alleged Infringement of the ’273 Patent and the ’621 Patent
73. Apple denies each and every allegation of Paragraph 73.
75. Apple admits that Ericsson provided a copy of this Complaint to Apple in advance
purports to allege that the Accused Products infringe the asserted independent claims of the ’273
and ’621 patents, respectively. Apple denies each and every remaining allegation of Paragraph
75.
’273 patent, and Exhibit 13 to this Complaint purports to be a claim chart of the ’621 patent. Apple
denies that any of the Accused Products infringe any valid and enforceable Asserted Claim of the
’273 patent or any valid and enforceable Asserted Claim of the ’621 patent. Apple denies each
and every remaining allegation of Paragraph 76.
C. Alleged Infringement of the ’770 Patent
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purports to allege that the Accused Products infringe an Asserted Claim of the ’770 patent. Apple
denies each and every remaining allegation of Paragraph 79.
80.
D. Alleged Infringement of the ’400 Patent
purports to allege that the Accused Products infringe the asserted independent claims of the ’400
patent. Apple denies each and every remaining allegation of Paragraph 83
84.
VIII. HARMONIZED TARIFF SCHEDULE ITEM NUMBERS
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85. Apple admits that the Harmonized Tariff Schedule item numbers for the Accused
Products imported into the United States are 8517.62.0090, 8518.22.0000, 8525.50.1000, 8517.13,
and 8471.30.01.
IX. RELATED LITIGATION
A. Litigation Related to the Asserted Patents
86. Apple admits that Ericsson filed an action for patent infringement against Apple in
the United States District Court for the Western District of Texas on January 17, 2022, Civil Action
No. 6:22-cv-61, asserting the Asserted Patents. Apple denies that it has infringed in any way any
claim of the Asserted Patents and denies that Ericsson is entitled to any relief. To the extent not
specifically and expressly admitted, Apple denies all other allegations and characterizations in
Paragraph 86.
87. Apple admits that the ’430 patent was asserted in the Commission Investigation
Certain Electronic Devices with Wireless Connectivity, Components Thereof, and Products
Containing the Same, Inv. No. 337-TA-1245, which was instituted on February 2, 2021. Apple
admits that the private parties filed a motion to terminate the investigation based on a settlement
agreement. Apple admits that the presiding Administrative Law Judge granted the motion, and
that decision was not reviewed by the Commission, and that the investigation was terminated on
August 2, 2021. Apple denies that it has infringed in any way any claim of the ’430 patent and
denies that Ericsson is entitled to any relief. To the extent not specifically and expressly admitted,
Apple denies all other allegations and characterizations in Paragraph 87.
88. Apple admits that the ’430 patent was asserted in an action for patent infringement
against Apple in the United States District Court for the Eastern District of Texas, Civil Action
No. 15-cv-288, filed on February 26, 2015. Apple admits that this action was dismissed on
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December 28, 2015. Apple denies that it has infringed in any way any claim of the ’430 patent
and denies that Ericsson is entitled to any relief. To the extent not specifically and expressly
89. Apple is without knowledge or information sufficient to form a belief as to the truth
of the allegations of Paragraph 89, and, on that basis, denies them.
B. Other Litigation Between the Parties
95. Apple admits that on January 17, 2022, Ericsson filed an action for patent
infringement against Apple in the United States District Court for the Western District of Texas,
Civil Action No. 6:22-cv-60. Apple denies that it has infringed in any way any claim of any patents
asserted in that action, and denies that Ericsson is entitled to any relief.
96. Apple admits that on January 17, 2022, Ericsson filed a patent infringement
complaint against Apple in Certain Mobile Telephones, Tablet Computers with Cellular
Connectivity, and Smart Watches with Cellular Connectivity, Components Thereof, and Products
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Containing Same, Inv. No. 337-TA-1299. Apple admits that additional cases were filed by
Ericsson outside the United States. Apple denies that it has infringed any claim of any patents
asserted in these actions. Apple denies that Ericsson is entitled to any relief.
97. Apple admits that on February 26, 2015, Ericsson filed a patent infringement
complaint against Apple in Certain Electronic Devices, Including Wireless Communication
Devices, Tablet Computers, Digital Media Players, and Cameras, Inv. No. 337-TA-952, which
was instituted on March 30, 2015. Apple admits that that investigation was terminated based on
settlement between the parties. Apple denies that it has infringed any claim of any patents asserted
in that investigation. Apple denies that Ericsson is entitled to any relief.
98. Apple admits that on February 26, 2015, Ericsson filed a patent infringement
complaint against Apple in Certain Wireless Standard Compliant Electronic Devices, Including
Communication Devices and Tablet Computers, Inv. No. 337-TA-953, which was instituted on
March 30, 2015. Apple admits that that investigation was terminated based settlement between
the parties. Apple denies that it has infringed any claim of any patents asserted in that
investigation. Apple denies that Ericsson is entitled to any relief.
99. Apple admits that on October 4, 2021, Ericsson filed a complaint against Apple in
the United States District Court for the Eastern District of Texas, Civil Action No. 2:21-cv-376,
where Ericsson does not assert patent infringement of the Asserted Patents.
100. Apple admits that on December 17, 2012, it brought suit against Ericsson in the
United States District Court for the Eastern District of Texas, Civil Action No. 2:21-cv-460.
101. Apple admits that Ericsson and Apple have been opposing parties in the following
Patent and Trademark Appeals Board proceedings:
i) Apple Inc. v. Ericsson Inc., IPR2015-01905
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ii) Apple Inc. v. Ericsson Inc., IPR2015-01904
iii) Apple Inc. v. Ericsson Inc., IPR2015-01919
iv) Apple Inc. v. Telefonaktiebolaget LM Ericsson, IPR2016-00004
v) Apple Inc. v. Telefonaktiebolaget LM Ericsson, IPR2016-00050
vi) Apple Inc. v. Ericsson Inc., IPR2016-00108
vii) Apple Inc. v. Ericsson Inc., IPR2016-00107
viii) Apple Inc. v. Ericsson Inc., IPR2016-00106
ix) Apple Inc. v. Telefonaktiebolaget LM Ericsson, IPR2016-00110
x) Apple Inc. v. Telefonaktiebolaget LM Ericsson, IPR2016-00109
xi) Apple Inc. v. Telefonaktiebolaget LM Ericsson, IPR2016-00154
xii) Apple Inc. v. Ericsson Inc., IPR2016-00152
102. Apple admits that Ericsson and Apple have been opposing parties in the following
district court proceedings:
i) Apple Inc. v. Telefonaktiebolaget LM Ericsson et al., 3-15-cv-00154
(NDCA)
ii) Ericsson Inc. et al. v. Apple Inc., 2:15-cv-00293 (EDTX)
iii) Ericsson Inc. et al. v. Apple Inc., 2:15-cv-00292 (EDTX)
iv) Ericsson Inc. et al. v. Apple Inc., 2:15-cv-00291 (EDTX)
v) Ericsson Inc. et al. v. Apple Inc., 2:15-cv-00290 (EDTX)
vi) Ericsson Inc. et al. v. Apple Inc., 2:15-cv-00289 (EDTX)
vii) Ericsson Inc. et al. v. Apple Inc., 2:15-cv-00287 (EDTX)
103. Apple admits that Ericsson and Apple have been opposing parties in the foreign
proceedings listed in Paragraph 103.
23
Inv. No. 337-TA-1300
104. The allegations of Paragraph 104 are too vague and ambiguous to admit or deny.
Apple admits that Ericsson and Apple are opposing parties in the foreign action
Telefonaktiebolaget LM Ericsson v. Apple Retail Netherlands BV, Apple Benelux BV, Apple Inc.,
Apple Distribution International and Apple Sales International, C/09/500495/HA ZA 15/1321.
X. DOMESTIC INDUSTRY
the allegations and characterizations in Paragraph 105 and, on that basis, denies them.
A. Ericsson’s Domestic Industry
24
Inv. No. 337-TA-1300
B. Samsung’s Domestic Industry
25
Inv. No. 337-TA-1300
118. Apple lacks knowledge or information sufficient to form a belief regarding the truth
of the allegations and characterizations in Paragraph 118 and, on that basis, denies them.
necessary. Apple states that the Initial Determination in Certain Electronic Devices, Including
Wireless Communications Devices, Portable Music and Data Processing Devices, and Tablet
Computers, Inv. No. 337-TA-794 (Sept. 14, 2012) speaks for itself and denies the allegations in
Paragraph 123 to the extent they purport to attribute to the Initial Determination anything not stated
therein. Apple lacks knowledge or information sufficient to form a belief regarding the truth of
26
Inv. No. 337-TA-1300
C. Ericsson’s Domestic Licensing
Licensing Activities
27
Inv. No. 337-TA-1300
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Inv. No. 337-TA-1300
Litigation Activities Related to Unwilling Licensees
XI. RELIEF REQUESTED
necessary. To the extent that any response to Paragraph 144 is required, Apple denies that Ericsson
has any valid cause of action pursuant to Section 337 of the Tariff Act of 1930, as amended. Apple
further denies that it has violated 19 U.S.C. § 1337 and specifically denies all of Ericsson’s
allegations of violation. Apple further denies that Ericsson is entitled to any relief whatsoever by
way of its Complaint. Apple denies any remaining allegations of Paragraph 144.
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Inv. No. 337-TA-1300
APPLE’S RESPONSE TO THE NOTICE OF INVESTIGATION
1. Pursuant to Commission Rule 210.13(b), Apple hereby responds to the Notice of
Institution of Investigation (the “Notice”) issued by the Commission on February 17, 2022, and
published in the Federal Register on February 24, 2022. Without admitting any of the specific or
general allegations set forth in the Complaint, as referenced in the Notice, Apple provides the
following response:
2. Apple acknowledges that the Commission has instituted an Investigation as set
forth in the Notice.
3. Apple denies that there has been any violation of Section 337 by reason of the
alleged infringement of any valid Asserted Claim of any Asserted Patent. Apple further contends
that the Asserted Claims of the Asserted Patents are invalid and/or unenforceable and cannot
support any remedy for the alleged infringement.
4. Apple denies that a protectable domestic industry, as required by 19 U.S.C.
§1337(a)(2)-(3), exists with respect to any of the Asserted Patents. Apple further denies that it is
in the public interest to grant any relief to Ericsson in connection with this Investigation.
5. Apple denies that Ericsson is entitled to any relief in this Investigation.
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Inv. No. 337-TA-1300
RESPONSE TO THE PUBLIC INTEREST STATEMENT OF COMPLAINANTS
Apple hereby incorporates by reference the entirely of its “Public Interest Statement of
Proposed Respondent Apple Inc.,” submitted to the Commission on February 1, 2022.
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Inv. No. 337-TA-1300
APPLE’S STATEMENT UNDER 19.C.F.R. § 210.13(B)
1. Pursuant to Rule 210.13(b), Apple provides the following additional information.
By providing such information, Apple intends only to supply data required by 19 C.F.R.
§ 210.13(b). Apple specifically denies that any of the supplied data refers to any unlawful act
under Section 337 or otherwise, and Apple specifically denies that it infringes any Asserted
Claim of the Asserted Patents based on the Accused Products. Discovery has only recently
begun, and is ongoing. Apple reserves the right to amend and/or supplement the information
provided below and in Confidential Exhibit A.
2. Attached as Confidential Exhibit A to this Response is the approximate statistical
data related to quantity of and revenue associated with imports of Apple Watch, HomePod,
Apple TV, iPhone, and iPad in fiscal year 2021.
3. The Harmonized Tariff Schedule item numbers for the Accused Products
imported into the United States are as follows:
Product Category Harmonized Tariff Schedule Item Number

Apple Watch 8517.62.0090
HomePod 8518.22.0000
Apple TV 8525.50.1000
iPhone 8517.13
iPad 8471.30.01
4. Apple has relied on and currently relies on third parties to manufacture the
Accused Products. The names and addresses of Apple’s suppliers of Accused Products are set
forth in Confidential Exhibit A attached hereto.
5. Apple believes that the United States is a significant market for the Accused
Products and is important to Apple’s overall operations. Apple’s statement as to the relative
significance of the United States market regarding the Accused Products to its operations is
further set forth in Confidential Exhibit A attached hereto.

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Inv. No. 337-TA-1300
fADDITIONAL DEFENSES
1. Apple asserts the following defenses in response to the allegations set forth in the
Complaint. Apple’s inclusion of these additional defenses in this Response is not a concession
that Apple bears the burden of proof with respect to any of them. Discovery has recently begun
and Apple has not yet had sufficient time or opportunity to collect and review all the information
that may be relevant to the matters and issues raised herein. Thus, pursuant to 19 U.S.C.
§§ 210.14(b) and 210.14(c), Apple reserves the right to seek to amend, modify, and/or expand
these defenses and to take further positions as discovery proceeds in this Investigation.
FIRST ADDITIONAL DEFENSE (NONINFRINGEMENT)
2. Although Apple does not bear the burden of proof on this issue, Apple has not,
and does not, directly infringe, indirectly infringe, induce infringement, or contribute to
infringement of any valid and enforceable claim of the Asserted Patents, either literally or under
the doctrine of equivalents, and has not otherwise committed any acts in violation of 35 U.S.C.
§ 271 and/or 19 U.S.C. § 1337.
3. Ericsson has failed to identify its contentions with respect to what articles are
accused of infringement and how the Accused Products practice each limitation of the Asserted
Claims of the Asserted Patents.
SECOND ADDITIONAL DEFENSE (INVALIDITY)
4. On information and belief, one or more claims of the Asserted Patents are invalid
for failing to comply with the requirements of 35 U.S.C. §§ 101, 102, 103, 112 and/or any other
applicable statutory provisions of Title 35 of the United States Code.
5. Apple provides an identification of prior art that supports this defense in Exhibit
B to this Response. The prior art provided in Exhibit B is exemplary only and should not be
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Inv. No. 337-TA-1300
construed as limiting in any way the defenses that Apple will present in this Investigation.
Apple’s investigation is ongoing. Further, nothing herein should be construed as an admission
that Apple agrees with any of Ericsson’s express or implied claim constructions.
6. Depending on the scope of the Asserted Claims of the Asserted Patents or
Complainants’ contentions in connection therewith, the Asserted Claims of the Asserted Patents
may be invalid for failure to provide an adequate written description or enabling disclosure, or
for failure to disclosure the best mode under 35 U.S.C. § 112, first paragraph, or for
indefiniteness under 35 U.S.C. § 112, second paragraph.
THIRD ADDITIONAL DEFENSE (LACK OF DOMESTIC INDUSTRY)
7. Although Apple does not bear the burden of proof on this issue, on information
and belief, Complainants have not adequately alleged and cannot prove the existence of a
domestic industry as required under 19 U.S.C. § 1337(a)(2)-(3), in connection with the Asserted
Patents. For example, on information and belief, Ericsson does not maintain a presence in the
domestic mobile phone, tablet computer, smart watch, smart speaker, and digital media player
market. Ericsson is therefore a non-practicing entity in the wireless phone, tablet, and watch
market.
FOURTH ADDITIONAL DEFENSE (LACK OF UNFAIR ACT)
8. Although Apple does not bear the burden of proof on this issue, on information
and belief, Apple has committed no unfair act that constitutes a violation of 19 U.S.C. § 1337.
FIFTH ADDITIONAL DEFENSE

(REQUESTED REMEDY IS NOT IN THE PUBLIC INTEREST)
9. Ericsson’s demand for relief is not in the public interest under Section 337(d)(1).
As explained further in “Public Interest Statement of Proposed Respondent Apple Inc.,”
submitted to the Commission on February 1, 2022, any exclusion order(s) or cease-and-desist

34
Inv. No. 337-TA-1300
order(s) would adversely affect the public health and welfare, competitive conditions in the
United States economy, the production of like or directly competitive articles in the United
States, and/or United States consumers.
10. In addition, Ericsson’s demand for an exclusion order and a cease and desist order
based on the Asserted Patents is not in the public interest because it is an attempt to use this
investigation (and its other litigation in the United States and around the world) to coerce Apple
into taking a portfolio-wide license to thousands of Ericsson patents, including standard essential
patents (“SEP”) that Ericsson committed to license on fair, reasonable, and non-discriminatory
(“FRAND”) terms. While Ericsson has not declared that the patents asserted in this investigation
are SEPs, Ericsson states that it uses patent litigation of “representative” patents to force a
license of a portfolio of patents: “[i]n instances where companies use Ericsson’s patent
technology, but after appropriate notice, negotiations, and opportunities, are unwilling to enter
into a license agreement, Ericsson invests in patent enforcement litigation. In those patent
enforcement proceedings, Ericsson asserts representative patents from the applicable portfolios.”
Complaint at ¶ 140 (emphasis added). Moreover, Ericsson never gave Apple any “notice,
negotiation, or opportunity” to take a license to just the Asserted Patents. Ericsson’s demand for
relief adversely affects the competitive conditions in the United States economy for at least two
reasons. First, when Ericsson demands that Apple take a license to its SEPs to avoid an
exclusion order on the Asserted Patents, Ericsson is impermissibly abrogating its FRAND
obligations. Ericsson promised to license its declared SEPs under fair and reasonable terms, and
using the threat of injunctive relief in this Investigation to coerce Apple into taking an SEP
license is a breach of that agreement. Second, when Ericsson demands that Apple take a license
to all of Ericsson’s patents to avoid an exclusion order on the Asserted Patents as
35
Inv. No. 337-TA-1300
“representative,” Ericsson is illegally tying the broad SEP portfolio license to the non-essential
Asserted Patents.
11. The public interest, therefore, precludes issuance of the requested remedial orders
in accordance with 19 U.S.C. § 1337(d)(1) and (f)(1).
SIXTH ADDITIONAL DEFENSE (ESTOPPEL)
12. On information and belief, and subject to further discovery, Ericsson is estopped
from asserting and construing any Asserted Claim to have been infringed by any Apple product
and asserting infringement by any Apple product under the doctrine of equivalents, in whole or
in part, by argument-based estoppel, prosecution history estoppel, and collateral, administrative,
and judicial estoppel, by virtue of the cancellations, amendments, arguments, representations,
and concessions made to the Patent and Trademark Office during the pendency of the
applications for the Asserted Patents and for related patents and patent applications, post-grant
proceedings, pending or prior litigation, and prior investigations by the International Trade
Commission.
SEVENTH ADDITIONAL DEFENSE

(EXPRESS/IMPLIED LICENSE AND/OR PATENT EXHAUSTION)
13. On information and belief, Ericsson’s claims are barred as a result of patent
exhaustion and/or a license to the Asserted Patents. Apple and/or its customer cannot be held
liable for infringement because the Accused Products were manufactured, sold, offered for sale,
used, and/or imported into the United States under an express and/or implied license from
Ericsson and/or its affiliates, and/or another licensed third party. For example, Apple is licensed
to the extent any agreement between Ericsson and an Apple contract manufacturer extends to
Apple or any Accused Products. Further, to the extent the claims of one or more of the Asserted
Patents are licensed by an Apple contract manufacturer and/or substantially embodied in an end
36
Inv. No. 337-TA-1300
product or component purchased by Apple from a seller authorized by Ericsson, Ericsson’s
patent rights are exhausted.
14. Apple has a license (express or implied) to practice one or more of the Asserted
Patents, and/or Apple has authority to practice the patents, or the patents are unenforceable
against Apple, on one or more of the following grounds: estoppel, laches, waiver, unclean hands,
and/or other applicable equitable doctrines.
EIGHTH ADDITIONAL DEFENSE (GOVERNMENT SALES)
15. Apple’s importations for, and sales to, the United States government are not
subject to the relief requested by Ericsson.
NINTH ADDITIONAL DEFENSE (UNCLEAN HANDS)
16. On information and belief, Ericsson’s claims as they relate to the Asserted Patents
are barred in whole or in part by reason of equitable doctrine of unclean hands. Ericsson comes
to the Investigation with unclean hands because it has engaged in a continuing anticompetitive
scheme, evidenced by Ericsson improperly seeking to invoke the Commission’s authority to
exclude the allegedly infringing Apple products from the United States.
TENTH ADDITIONAL DEFENSE (INEQUITABLE CONDUCT)
17. On information and belief, and subject to further discovery, the Asserted Patents
are unenforceable due to the inequitable conduct of the named inventors and/or the prosecuting
attorneys for the Asserted Patents.
ELEVENTH ADDITIONAL DEFENSE (ENSNAREMENT)
18. On information and belief, and subject to further discovery, Ericsson’s
infringement claims are barred by the doctrine of ensnarement. Ericsson is foreclosed from
asserting infringement under the doctrine of equivalents to the extent the scope of such
equivalent would ensnare prior art.

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Inv. No. 337-TA-1300
TWELFTH ADDITIONAL DEFENSE (PATENT MISUSE)
19. Ericsson is and has committed patent misuse by using the threat of exclusion
order based on the Asserted Patents to coerce Apple into taking a license to thousands of
Ericsson SEPs at rates that are not FRAND. As Ericsson pled in its Complaint, “[i]n instances
where companies use Ericsson’s patent technology, but after appropriate notice, negotiations,
and opportunities, are unwilling to enter into a license agreement, Ericsson invests in patent
enforcement litigation. In those patent enforcement proceedings, Ericsson asserts representative
patents from the applicable portfolios.” Complaint at ¶ 140 (emphasis added). Ericsson thus
admits that it is using the coercive threat of an exclusion order of “representative” patents to
force a license of a “portfolio” of patents. Moreover, Ericsson never gave Apple any “notice,
negotiation, or opportunity” to take a license to just the Asserted Patents. Ericsson’s actions
constitute misuse in two forms. First, when Ericsson demands that Apple take a license to its
SEPs to avoid an exclusion order on the Asserted Patents, Ericsson is impermissibly abrogating
its FRAND obligations. Ericsson promised to license its declared SEPs under fair and
reasonable terms, and using the threat of injunctive relief in this Investigation to coerce Apple
into taking an SEP license is a breach of that agreement. Second, when Ericsson demands that
Apple take a license to all of Ericsson’s patents to avoid an exclusion order on the Asserted
Patents as “representative,” Ericsson is illegally tying the broad SEP portfolio license to the non-
essential Asserted Patents.
THIRTEENTH ADDITIONAL DEFENSE (INVENTORSHIP)
20. Upon information and belief, and subject to the further discovery, Ericsson’s
Asserted Claims are unenforceable to the extent that the alleged inventors did not invent the
purported inventions, or to the extent that the actual inventors are not named as inventors.
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Inv. No. 337-TA-1300
FOURTEENTH ADDITIONAL DEFENSE (OTHER DEFENSES)
21. Apple further reserves the right to amend its Response to include other affirmative
defenses that Apple may learn of during the course of this Investigation.
PRAYER FOR RELIEF
WHEREFORE, Apple requests that the Commission issue an order:
1. Denying all relief requested in the Complaint;
2. Finding that Apple has not violated Section 337 of the Tariff Act of 1930, as
amended, 19 U.S.C. § 1337;
3. Finding that Apple does not directly infringe or induce infringement of any valid
and enforceable claim of the Asserted Patents, either literally or under the doctrine of equivalents,
and has not otherwise committed any acts in violation of 35 U.S.C. § 271 or 19 U.S.C. § 1337;
4. Finding that the Asserted Claims of the Asserted Patents are invalid;
5. Finding that there is no domestic industry for the Asserted Patents;
6. Complainants’ demands for relief are barred because of the relief’s effect upon
the public health and welfare, competitive conditions in the United States economy, the
production of like or directly competitive articles in the United States, and United States
consumers;
7. Finding that Complainants’ claims as they relate to the Asserted Patents are
barred by reason of equitable doctrines, including equitable estoppel, acquiescence, unclean
hands, prosecution laches, and/or waiver;
8. Awarding Apple its attorneys’ fees and costs incurred in responding to the
Complaint and defending this Investigation;
9. Dismissing the present Complaint and terminating the present Investigation;
39
Inv. No. 337-TA-1300
10. Finding that it is not in the public interest to grant any relief to Complainants; and
11. Awarding such other and further relief as the Commission deems just and proper.
40
Inv. No. 337-TA-1300
Respectfully submitted,
FISH & RICHARDSON P.C.
Dated: April 4, 2022 By: /s/ Benjamin C. Elacqua

Benjamin C. Elacqua
1221 McKinney Street, Suite 2800
Houston, TX 77010
Telephone: (713) 654-5300
Facsimile: (713) 652-0109
Betty Chen
500 Arguello Street
Suite 500
Redwood, CA 94063
Telephone: (650) 839-5070
Facsimile: (650) 839-5071
Ruffin B. Cordell
Richard A. Sterba
1000 Maine Avenue, S.W., Suite 1000
Telephone: (202) 783-5070
Facsimile: (202) 783-2331
Aamir Kazi
Benjamin Thompson
Jacqueline Tio
Katherine Reardon
1180 Peachtree St SE, Suite 2100
Atlanta, GA 30309
Telephone: (404) 892-5005
Facsimile: (404) 892-5002
Andrew Pearson
Whitney Reichel
One Marina Park Drive
Boston, MA 02210
Telephone: (617) 542-5070
Counsel for Respondent Apple Inc.

41
Inv. No. 337-TA-1300
VERIFICATION
I, Mark Rollins, am a Finance Manager at Apple Inc. I am authorized to make this
verification on behalf of Apple Inc. I have read RESPONDENT APPLE INC.’S RESPONSE
TO THE COMPLAINT OF ERICSSON INC. AND TELEFONAKTIEBOLAGET LM
ERICSSON UNDER SECTION 337 OF THE TARIFF ACT OF 1930, AS AMENDED, AND
NOTICE OF INVESTIGATION and know its contents.
To the best of my knowledge, information, and belief, formed after a reasonable inquiry,
I verify that the facts set forth in this Response (excluding facts related to Ericsson’s confidential
business information, which I am not permitted to see) and accompanying Exhibit A are true and
correct as of the date indicated below. My information and belief may be based on statements,
reports, and records of other Apple employees upon whom I customarily rely.
Dated: April 3, 2022 _____________________
Mark Rollins
CERTIFICATE OF SERVICE
I hereby certify that true and correct copies of the foregoing document:
RESPONDENT APPLE INC.’S RESPONSE TO THE COMPLAINT OF

ERICSSON INC. AND TELEFONAKTIEBOLAGET LM ERICSSON UNDER
SECTION 337 OF THE TARIFF ACT OF 1930, AS AMENDED,
AND NOTICE OF INVESTIGATION
have been filed and served on this 4th day of April, 2022, on the following:
Lisa R. Barton Via First Class Mail

Secretary to the Commission Via Hand Delivery
U.S. International Trade Commission Via Federal Express
500 E Street, S.W. Via Electronic Filing
The Honorable MaryJoan McNamara Via First Class Mail

Administrative Law Judge Via Hand Delivery
U.S. International Trade Commission (two double sided paper copies)
500 E Street, S.W., Room 317 Via Federal Express
Washington, D.C. 20436 Via Electronic Mail
Email: McNamara337@usitc.gov
Andrew Beverina Via First Class Mail

Sarah Sladic Via Hand Delivery
Office of Unfair Import Investigations Via Federal Express
Via Electronic Mail
U.S. International Trade Commission
500 E Street, S.W., Room 317 Via USITC Box Platform
Email: andrew.beverina@usitc.gov
Email: sarah.sladic@usitc.gov
Thomas L. Jarvis Via First Class Mail

Winston & Strawn LLP Via Hand Delivery
1901 L Street, N.W. Via Federal Express
Washington, D.C. 20036 Via Electronic Mail
Email: ITC1300WinstonService@winston.com
Email: Ericsson.ITC1300@FisherBroyles.com
Counsel for Complainants Complainants Ericsson Inc. and

Telefonaktiebolaget LM Ericsson
/s/ Ashley Cox

Confidential
Exhibit A
Filed Under Seal
Exhibit B
UNITED STATES INTERNATIONAL TRADE COMMISSION
WASHINGTON, D.C.
Before the Honorable MaryJoan McNamara

Administrative Law Judge
In the Matter of
CERTAIN MOBILE PHONES, TABLET

COMPUTERS, SMART WATCHES, Inv. No. 337-TA-1300
SMART SPEAKERS, AND DIGITAL
MEDIA PLAYERS, AND PRODUCTS
CONTAINING SAME
EXHIBIT B: IDENTIFICATION OF EXEMPLARY PRIOR ART TO THE

ASSERTED PATENTS
Inv. No. 337-TA-1300

Exhibit B to Apple’s Response to the Complaint and Notice
I. Identification of Exemplary Prior Art to U.S. Patent No. 7,151,430
A. U.S. Patent Publications
1. U.S. Patent No. 5,602,556 (“Bowers”)
2. U.S. Patent No. 5,450,263 (“Desaigoudar”)
3. U.S. Patent No. 6,988,307 (“Gardner”)
4. U.S. Patent No. 6,549,077 (“Jou”)
5. U.S. Patent Application Publication No. 2005/0237144 A1 (“Einzinger

’144”)
6. U.S. Patent No. 6,894,598 (“Heima”)
7. U.S. Patent No. 5,245,307 (“Klaus”)
8. U.S. Patent No. 4,201,965 (“Onyshkevych”)
9. U.S. Patent No. 3,962,946 (“Rickard”)
10. U.S. Patent No. 5,966,063 (“Sato”)
11. U.S. Patent No. 5,777,538 (“Schuetz”)
12. U.S. Patent No. 5,682,098 (“Vij”)
13. U.S. Patent No. 7,141,883 (“Wei”)
14. U.S. Patent No. 6,194,987 (“Zhou”)
15. U.S. Patent No. 4,135,183 (“Heltemes”)
16. U.S. Patent No. 6,433,781 (“Oda”)
17. U.S. Patent No. 7,342,548 (“Tanigichi”)
18. U.S. Patent No. 5,451,914 (“Stengel”)
19. U.S. Patent No. 6,281,778 (“El-Sharawy”)
20. U.S. Patent Application Publication No. 2003/0063034 (“Taniguchi”)
21. U.S. Patent No. 7,199,682 (“Ezzeddine”)
22. U.S. Patent No. 6,529,720 (“Jovenin”)
B. Foreign Patent Publications

Inv. No. 337-TA-1300
1. International Patent Application No. WO 98/05048 A1 (“Midya”)
2. International Patent Application No. WO 2004/012213 (“Einzinger ’213”)
3. Japanese Patent Publication No. JPH11272827 (“Ishii”)
4. European Patent Publication No. EP 0 645 840 (“Rebers”)
5. European Patent Publication No. EP 0 766 200 A2 (“Saithoh”)
6. International Patent Application No. WO 99/049513 A1 (“Zhou”)
7. Japanese Patent Publication No. JPS6383682 A (“Komatsu”)
8. European Patent Publication No. EP 0 492 261 A2 (“Kajola”)
9. French Patent Publication No. FR 2 805 618 B1 (“Acher”)
C. Non-Patent Publications
1. New Planar Inductor Arranged Unit Spiral Coil, Ishbashi et al., IEEE
International Magnetics Conference (INTERMAG), ISBN: 0-7803-1310-0
(1993).
2. The Art of Analog Layout, Alan Hastings, First Edition (2001) ISBN 0-13-
087061-7, Prentice-Hall, Inc.
3. Simple Accurate Expressions for Planar Spiral Inductances, Sunderarajan

S. Mohan, Maria del Mar Hershenson, Stephen P. Boyd, and Thomas H.
Lee, IEEE Journal of Solid-State Circuits, Vol. 34, No. 10, October 1999.
4. A 1.8-Ghz Low-Phase-Noise CMOS VCO Using Optimized Hollow Spiral

Inductors, Jan Craninckx, et al, IEEE Journal of Solid-State Circuits, vol.
32, no. 5, pp. 736-744.
5. A Study of Phase Noise in CMOS Oscillators, B. Razavi, IEEE Journal of

Solid-State Circuits, vol. 31, pp. 331–343, Mar. 1996.
6. Physics, Holiday, 3rd edition, 1978.
7. Antenna Theory: A Review, Constantine A. Balanis, Proceedings of the

IEEE, vol. 80, no. 1, January 1992.
8. Low Supply Voltage Fully Integrated CMOS VCO with Three Terminals
spiral inductor, N. Itoh; B. De Muer; M. Steyaert, Proceedings of the 25th
European Solid-State Circuits Conference, 1999.
9. Impact of Mutual Inductance and Parasitic Capacitance on the Phase-

Error Performance of CMOS Quadrature VCOS, Xiaoyan Wang, P.
Inv. No. 337-TA-1300

Andreani, 2003 IEEE International Symposium on Circuits and Systems
(ISCAS).
10. Field and Wave Electromagnetics, 2nd edition by David K. Cheng, 1989.
11. A Twisted-Bundle Layout Structure for Minimizing Inductive Coupling

noise, G. Zhong; C.-K. Koh;K. Roy, IEEE/ACM International Conference
on Computer Aided Design. ICCAD - 2000.
12. Impact of Mutual Inductance and Parasitic Capacitance on the Phase-

Error Performance of CMOS Quadrature VCOs, X. Wang and P.
Andreani, Proceedings of the 2003 International Symposium on Circuits
and Systems, ISCAS 03, Bangkok, Thailand, May 25-28, 2003.
13. Development of Multichannel SQUID Magnetometers for Neuromagnetic

Measurements, J. Knuutila, Ph.D. thesis, 1987, ISBN 951-99903-6-4.
14. Integrated Thin Film SQUID Instruments, G.B. Donaldson et al.,

SQUID‘85 Superconducting Quantum Interference Devices and their
Applications, Proc. 3 Int. Conf. on Superconducting Quantum Devices,
Berlin, June 25-28, 1985, Editors Hahlbohm/Lübbig, Walter de Gruyter
&Co., Berlin/New York.
15. Integrated Thin-Film DC SQUID Sensors, M.B. Ketchen, IEEE

Transactions on Magnetics, Vol. MAG-23, No. 2, March 1987.
D. Prior Art Systems
1. California Institute of Technology’s 7HP1 Prototype of a Power Amplifier

(“7HP1 System”)
2. California Institute of Technology’s 7HP2 Prototype of a Power Amplifier

(“7HP2 System”)
3. California Institute of Technology’s SOI Prototype of a Power Amplifier

(“SOI System”)
II. Identification of Exemplary Prior Art to U.S. Patent No. 9,509,273
1. U.S. Patent No. 2,021,734 (“Macalpine”)
2. U.S. Patent No. 4,012,703 (“Chamberlayne”)
3. U.S. Patent No. 5,907,236 (“James”)
4. U.S. Patent No. 6,384,581 (“Sen”)
Inv. No. 337-TA-1300

5. U.S. Patent No. 6,717,502 (“Yue”)
6. U.S. Patent Application Publication No. 2003/0186667 (“Wallace”)
7. U.S. Patent Application Publication No. 2006/0270377 (“Bhatti”)
8. U.S. Patent Application Publication No. 2006/0273870 (“Yeung”)
9. U.S. Patent Application Publication No. 2010/0026411 (“Liu”)
10. U.S. Patent Application Publication No. 2010/0154517 (“Sammoura”)
11. U.S. Patent Application Publication No. 2010/0109806 (“Kim”)
13. U.S. Patent No. 6,621,363 (“Park”)
14. U.S. Patent No. 7,305,223 (“Liu 2”)
15. U.S. Patent No. 7,755,448 (“Zolomy”)
16. U.S. Patent No. 8,120,447 (“Taniguchi”)
17. U.S. Patent Application Publication No. 2003/0095007 (“Suzuki”)
18. U.S. Patent No. 6,046,641 (“Chawla”)
19. U.S. Patent No. 8,229,385 (“Bhagat”)
20. U.S. Patent No. 8,416,022 (“Kawakami”)
21. U.S. Patent No. 9,484,334 (“Frye”)
22. U.S. Patent No. 9,741,714 (“Gertenach”)
23. U.S. Patent Application Publication No. 2004/0145928 (“Takada”)
24. U.S. Patent Application Publication No. 2011/0128084 (“Jin”)
25. U.S. Patent Application Publication No. 2011/0241781 (“Owen”)
26. U.S. Patent No. 6,448,873 (“Mostov”)
27. U.S. Patent No. 7,522,691 (“Katakura”)
28. U.S. Patent No. 9,166,564 (“Koechlin”)
29. U.S. Patent No. 9,177,712 (“Chen”)
Inv. No. 337-TA-1300

30. U.S. Patent Application Publication No. 2008/0258838 (“Oshima”)
31. U.S. Patent Application Publication No. 2011/0128054 (“Kerkman”)
32. U.S. Patent Application Publication No. 2011/0221505 (“Jiang”)
33. U.S. Patent Application Publication No. 2011/0241163 (“Liu 3”)
34. U.S. Patent No. 5,986,617 (“McLellan”)
35. U.S. Patent No. 7.449,974 (“Lee”)
36. U.S. Patent No. 6,061,252 (“Hosotani”)
37. U.S. Patent No. 6,690,586 (“Hosotani 2”)
38. U.S. Patent No. 7,279,851 (“Ball”)
39. U.S. Patent No. 8,791,769 (“Leong”)
41. U.S. Patent No. 5,886,589 (“Mourant”)
42. U.S. Patent No. 6,087,822 (“van der Veen”)
43. U.S. Patent No. 6,804,349 (“Prat”)
44. U.S. Patent No. 8,203,399 (“Kim 2”)
45. U.S. Patent No. 8,576,005 (“Liao)
46. U.S. Patent Application Publication No. 2010/0136942 (“Lee 2”)
48. U.S. Patent Application Publication No. 2011/0103100 (“Hosotani 3”)
49. U.S. Patent No. 5,477,204 (“Li”)
50. U.S. Patent No. 7,183,872 (“Lee 3”)
51. U.S. Patent No. 7,199,679 (“Mondal”)
52. U.S. Patent No. 7,825,746 (“Yeung”)
53. U.S. Patent Application Publication No. 2006/0197622 (“Eo”)
54. U.S. Patent No. 8,049,563 (“Aoki”)
Inv. No. 337-TA-1300

55. U.S. Patent No. 6,483,415 (“Tang”)
56. U.S. Patent No. 6,608,361 (“Chang”)
57. U.S. Patent No. 7,880,547 (“Lee 4”)
58. U.S. Patent No. 5,285,179 (“Wignot”)
59. U.S. Patent No. 6,861,922 (“Hasegawa”)
60. U.S. Patent Application Publication No. 2001/0054937 (“Hyvonen”)
61. U.S. Patent Application Publication No. 2005/0104679 (“Blednov”)
62. U.S. Patent Application Publication No. 2006/0273870 (“Yeung 2”)
63. U.S. Patent Application Publication No. 2009/0195324 (“Li”)
64. U.S. Patent Application Publication No. 2010/0194280 (“Kirchmeier”)
1. German Patent No. DE 906818 (“Koehler”)
2. Japanese Patent No. JP 2010154517 (“Yusuke”)
3. Korean Patent No. KR 2007120404 (“Chul”)
4. Japanese Patent No. JP 2003230274A (“Masayuki”)
5. Japanese Patent No. JP 4086154 (“TDK”)
6. Japanese Patent No. JP 2002083894A (“Yuji”)
7. Japanese Patent No. JP 2002280862A (“Koji”)
8. Japanese Patent No. JP 2008198929A (“Teru”)
9. Japanese Patent No. JP 2009164482A (“Teru 2”)
10. Japanese Patent No. JP 2010519857A (“Qualcomm”)
11. World Intellectual Property Organization Patent No. WO 2004/004118

(“Odendaal”)
12. Swiss Patent No. CH 275245 (“Hlavka”)
13. European Patent No. EP 0257291A1 (“Stein”)
14. European Patent No. EP 0539133B1 (“Huusko”)

Inv. No. 337-TA-1300
15. European Patent No. EP 1 685 575 (“Runge”)
1. Distributed Active Transformer—A New Power-Combining and

Impedance-Transformation Technique, Ichiro Aoki et al., IEEE
Transactions On Microwave Theory And Techniques, vol. 50, no. 1,
January 2002.
2. Fully Integrated CMOS Power Amplifier With Efficiency Enhancement at

Power Back-Off, Gang Liu et al., IEEE Journal Of Solid-State Circuits,
vol. 43, no. 3, March 2008.
3. Leakage Inductance Calculation Of Complex Transformer Constructions

Based On A Simple Two-Coil Inductor Model, YP Chan et al., The 37th
IEEE Power Electronics Specialists Conference 2006, (PESC'06), Jeju,
South Korea, 18-22 June 2006.
4. Scalable Compact Circuit Model for Differential Spiral Transformers in

CMOS RFICs, Wei Gao et al., IEEE Transactions On Electron Devices,
vol. 53, no. 9, September 2006.
5. Integrated Multi-Tap Transformer for Reconfigurable Multimode

Matching Networks, Xiaohua Yu et al., ISBN: 978-1-4244-9472-9, May
15, 2011.
6. Very Compact Transformer-Coupled Balun-Integrated Bandpass Filter

Using Integrated Passive Device Technology on Glass Substrate, Chien-
Hsun Chen et al., ISBN:978-1-4244-6057-1, May 23, 2010.
7. A Frequency-Independent Equivalent Circuit Model for Planar Symmetric

Balun in CMOS RFICs, Jiaju Wei, ISBN: 978-1-4244-5708-3, May 8,
2010.
8. Design of Integrated Planar Marchand Balun Using Physical Transformer

Model, C. –H. Huang et al., ISBN: 978-1-4244-2801-4, December 7,
2009.
9. Band-Pass-Filter with Balun Function from IPD Technology, Kai Liu et

al., ISBN: 978-1-4244-2230-2, 2008 Electronic Components and
Technology Conference.
10. Analysis, Design, and Optimization of Spiral Inductors and Transformers

for Si RF IC’s, Ali M. Niknejad et al., ISSN: 1558-173X, IEEE Journal Of
Solid-State Circuits, vol. 33, no. 10, October 1998.
11. Modelling and Analysis of Transformer Winding at High Frequencies,

Yoshikazu Shibuya et al., IEEE, International Conference on Power
Inv. No. 337-TA-1300

Systems Transients (IPST’05) in Montreal, Canada on June 19-23, 2005
Paper No. IPST05-025
12. The Modeling, Characterization, and Design of Monolithic Inductors for

Silicon RF IC’s, John R. Long, IEEE Journal Of Solid-State Circuits, vol.
32, no. 3, March 1997.
13. Passive and Active Filters: Theory and Implementations, Wai-Kai Chen,
ISBN 0-471-82352-X, John Wiley & Sons, Inc., 1986.
III. Identification of Exemplary Prior Art to U.S. Patent No. 9,853,621
1. U.S. Patent No. 2,021,734 (“Macalpine”)
2. U.S. Patent No. 4,012,703 (“Chamberlayne”)
4. U.S. Patent No. 6,384,581 (“Sen”)
5. U.S. Patent No. 6,717,502 (“Yue”)
6. U.S. Patent Application Publication No. 2003/0186667 (“Wallace”)
7. U.S. Patent Application Publication No. 2006/0270377 (“Bhatti”)
8. U.S. Patent Application Publication No. 2006/0273870 (“Yeung”)
9. U.S. Patent Application Publication No. 2010/0026411 (“Liu”)
10. U.S. Patent Application Publication No. 2010/0154517 (“Sammoura”)
13. U.S. Patent No. 6,621,363 (“Park”)
14. U.S. Patent No. 7,305,223 (“Liu 2”)
15. U.S. Patent No. 7,755,448 (“Zolomy”)
16. U.S. Patent No. 8,120,447 (“Taniguchi”)
17. U.S. Patent Application Publication No. 2003/0095007 (“Suzuki”)
18. U.S. Patent No. 6,046,641 (“Chawla”)
Inv. No. 337-TA-1300

19. U.S. Patent No. 8,229,385 (“Bhagat”)
20. U.S. Patent No. 8,416,022 (“Kawakami”)
21. U.S. Patent No. 9,484,334 (“Frye”)
22. U.S. Patent No. 9,741,714 (“Gertenach”)
23. U.S. Patent Application Publication No. 2004/0145928 (“Takada”)
24. U.S. Patent Application Publication No. 2011/0128084 (“Jin”)
25. U.S. Patent Application Publication No. 2011/0241781 (“Owen”)
26. U.S. Patent No. 6,448,873 (“Mostov”)
27. U.S. Patent No. 7,522,691 (“Katakura”)
28. U.S. Patent No. 9,166,564 (“Koechlin”)
29. U.S. Patent No. 9,177,712 (“Chen”)
30. U.S. Patent Application Publication No. 2008/0258838 (“Oshima”)
31. U.S. Patent Application Publication No. 2011/0128054 (“Kerkman”)
33. U.S. Patent Application Publication No. 2011/0241163 (“Liu 3”)
34. U.S. Patent No. 5,986,617 (“McLellan”)
35. U.S. Patent No. 7.449,974 (“Lee”)
36. U.S. Patent No. 6,061,252 (“Hosotani”)
37. U.S. Patent No. 6,690,586 (“Hosotani 2”)
38. U.S. Patent No. 7,279,851 (“Ball”)
39. U.S. Patent No. 8,791,769 (“Leong”)
41. U.S. Patent No. 5,886,589 (“Mourant”)
42. U.S. Patent No. 6,087,822 (“van der Veen”)
43. U.S. Patent No. 6,804,349 (“Prat”)
Inv. No. 337-TA-1300

44. U.S. Patent No. 8,203,399 (“Kim 2”)
45. U.S. Patent No. 8,576,005 (“Liao)
46. U.S. Patent Application Publication No. 2010/0136942 (“Lee 2”)
48. U.S. Patent Application Publication No. 2011/0103100 (“Hosotani 3”)
49. U.S. Patent No. 5,477,204 (“Li”)
50. U.S. Patent No. 7,183,872 (“Lee 3”)
51. U.S. Patent No. 7,199,679 (“Mondal”)
52. U.S. Patent No. 7,825,746 (“Yeung”)
53. U.S. Patent Application Publication No. 2006/0197622 (“Eo”)
54. U.S. Patent No. 8,049,563 (“Aoki”)
55. U.S. Patent No. 6,483,415 (“Tang”)
56. U.S. Patent No. 6,608,361 (“Chang”)
57. U.S. Patent No. 7,880,547 (“Lee 4”)
58. U.S. Patent No. 5,285,179 (“Wignot”)
59. U.S. Patent No. 6,861,922 (“Hasegawa”)
60. U.S. Patent Application Publication No. 2001/0054937 (“Hyvonen”)
61. U.S. Patent Application Publication No. 2005/0104679 (“Blednov”)
62. U.S. Patent Application Publication No. 2006/0273870 (“Yeung 2”)
63. U.S. Patent Application Publication No. 2009/0195324 (“Li”)
64. U.S. Patent Application Publication No. 2010/0194280 (“Kirchmeier”)
1. German Patent No. DE 906818 (“Koehler”)
2. Japanese Patent No. JP 2010154517 (“Yusuke”)
3. Korean Patent No. KR 2007120404 (“Chul”)
Inv. No. 337-TA-1300

4. Japanese Patent No. JP 2003230274A (“Masayuki”)
5. Japanese Patent No. JP 4086154 (“TDK”)
6. Japanese Patent No. JP 2002083894A (“Yuji”)
7. Japanese Patent No. JP 2002280862A (“Koji”)
8. Japanese Patent No. JP 2008198929A (“Teru”)
9. Japanese Patent No. JP 2009164482A (“Teru 2”)
10. Japanese Patent No. JP 2010519857A (“Qualcomm”)
11. World Intellectual Property Organization Patent No. WO 2004/004118

(“Odendaal”)
12. Swiss Patent No. CH 275245 (“Hlavka”)
13. European Patent No. EP 0257291A1 (“Stein”)
14. European Patent No. EP 0539133B1 (“Huusko”)
15. European Patent No. EP 1 685 575 (“Runge”)
1. Distributed Active Transformer—A New Power-Combining and

Impedance-Transformation Technique, Ichiro Aoki et al., IEEE
Transactions On Microwave Theory And Techniques, vol. 50, no. 1,
January 2002.
2. Fully Integrated CMOS Power Amplifier With Efficiency Enhancement at

Power Back-Off, Gang Liu et al., IEEE Journal Of Solid-State Circuits,
vol. 43, no. 3, March 2008.
3. Leakage Inductance Calculation Of Complex Transformer Constructions

Based On A Simple Two-Coil Inductor Model, YP Chan et al., The 37th
IEEE Power Electronics Specialists Conference 2006, (PESC'06), Jeju,
South Korea, 18-22 June 2006.
4. Scalable Compact Circuit Model for Differential Spiral Transformers in

CMOS RFICs, Wei Gao et al., IEEE Transactions On Electron Devices,
vol. 53, no. 9, September 2006.
5. Integrated Multi-Tap Transformer for Reconfigurable Multimode

Matching Networks, Xiaohua Yu et al., ISBN: 978-1-4244-9472-9, May
15, 2011.
Inv. No. 337-TA-1300

6. Very Compact Transformer-Coupled Balun-Integrated Bandpass Filter
Using Integrated Passive Device Technology on Glass Substrate, Chien-
Hsun Chen et al., ISBN:978-1-4244-6057-1, May 23, 2010.
7. A Frequency-Independent Equivalent Circuit Model for Planar Symmetric

Balun in CMOS RFICs, Jiaju Wei, ISBN: 978-1-4244-5708-3, May 8,
2010.
8. Design of Integrated Planar Marchand Balun Using Physical Transformer

Model, C. –H. Huang et al., ISBN: 978-1-4244-2801-4, December 7,
2009.
9. Band-Pass-Filter with Balun Function from IPD Technology, Kai Liu et

al., ISBN: 978-1-4244-2230-2, 2008 Electronic Components and
Technology Conference.
10. Analysis, Design, and Optimization of Spiral Inductors and Transformers

for Si RF IC’s, Ali M. Niknejad et al., ISSN: 1558-173X, IEEE Journal Of
Solid-State Circuits, vol. 33, no. 10, October 1998.
11. Modelling and Analysis of Transformer Winding at High Frequencies,

Yoshikazu Shibuya et al., IEEE, International Conference on Power
Systems Transients (IPST’05) in Montreal, Canada on June 19-23, 2005
Paper No. IPST05-025
12. The Modeling, Characterization, and Design of Monolithic Inductors for

Silicon RF IC’s, John R. Long, IEEE Journal Of Solid-State Circuits, vol.
32, no. 3, March 1997.
13. Passive and Active Filters: Theory and Implementations, Wai-Kai Chen,
ISBN 0-471-82352-X, John Wiley & Sons, Inc., 1986.
IV. Identification of Exemplary Prior Art to U.S. Patent No. 7,957,770
1. U.S. Patent No. 5,977,867 (“Blouin”)
2. U.S. Patent No. 6,785,563 (“Tsukamoto”)
3. U.S. Patent No. 6,963,762 (“Kaaresoja”)
4. U.S. Patent No. 7,616,192 B2 (“Schroeder”)
5. U.S. Patent No. 8,898,564 (“Grant”)
6. U.S. Patent No. 9,360,937 (“Rosenberg”)
7. U.S. Patent No. 9,645,836 B2 (“Rothkopf”)

Inv. No. 337-TA-1300
8. U.S. Patent Application Publication No. 2002/0149561 A1 (“Fukumoto”)
9. U.S. Patent Application Publication No. 2006/0128439 A1 (“Lee”)
10. U.S. Patent Application Publication No. 2006/0066569 A1 (“Eid”)
11. U.S. Patent Application Publication No. 2007/0190991 (“Cargille”)
12. U.S. Patent Application Publication No. 2007/0035527 (“Cheon”)
13. U.S. Patent Application Publication No. 2007/0024593 A1 (“Schroeder”)
14. U.S. Patent Application Publication No. 2008/0204266 A1 (“Malmberg

2008”)
15. U.S. Patent Application Publication No. 2009/0197648 A1 (“Cheon”)
16. U.S. Patent Application Publication No. 2017/0108931 A1 (“Gregorio”)
1. Canadian Patent No. 2,508,387 C (“Orr”)
2. European Patent Application No. 1139684 A1 (“Cho”)
3. German Patent No. 10,154,643 (“Hiebl”)
4. Japanese Patent No. 10145851 A (“Kanamaru”)
5. Japanese Patent No. 3560527 B2 (“Kuwahara”)
6. Korean Patent No. KR2001/0010775 A (“Young-hoo”)
7. Korean Patent No. KR2004/0103621 A (“Ju-byeong”)
8. Korean Patent No. KR2005/0096257 A (“Yoon”)
9. Korean Patent No. KR2006/059230 (“”)
10. UK Patent Application No. GB2248709 A (“Kunitomo”)
11. International Application No. WO 2005/085981A1 (“Malmberg 2005”)
1. Ambient Touch: Designing Tactile Interfaces for Handheld Devices

(“Poupyrev”)
2. The focus problem in mobile learning (“Goeth”)
Inv. No. 337-TA-1300

3. A Role for Haptics in Mobile Interaction: Initial Design Using a Handheld
Tactile Display Prototype (“Luk”)
4. Active Click: Tactile Feedback for Touch Panels (“ActiveClick”)
5. Novel interfaces for remote driving: gesture, haptic and PDA (“Fong”)
V. Identification of Exemplary Prior Art to U.S. Patent No. 9,705,400
1. U.S. Patent No. 5,506,493 (“Stengel”)
2. U.S. Patent Application Publication No. 2013/0057200 (“Potts”)
3. U.S. Patent No. 6,661,285 (“Pompei”)
4. U.S. Patent No. 7,615,979 (“Caldwell”)
5. U.S. Patent Application Publication No. 2002/0125941 (“Nguyen”)
6. U.S. Patent Application Publication No. 2006/0176036 (“Flatness”)
7. U.S. Patent No. 7,336,056 (“Dening”)
8. U.S. Patent No. 7,432,689 (“Miller”)
9. U.S. Patent Application Publication No. 2009/0102440 (“Coles”)
10. U.S. Patent Application Publication No. 2009/0295343 (“Chiu”)
11. U.S. Patent Application Publication No. 2010/0085028 (“Moussaoui”)
12. U.S. Patent Application Publication No. 2011/0037321 (“Chatterjee”)
13. U.S. Patent Application Publication No. 2014/0334189 (“Yan”)
14. U.S. Patent Application Publication No. 2016/0006371 (“Nesemann”)
15. U.S. Patent No. 6,798,271 (“Swize”)
16. U.S. Patent Application Publication No. 2014/0063882 (“Hirler ’882”)
17. U.S. Patent Application Publication No. 2012/0140958 (“Lin”)
18. U.S. Patent Application Publication No. 2009/0054023 (“Bean”)
19. U.S. Patent Application Publication No. US20120306464 (“Hirler ’464”)
20. U.S. Patent No. 5,757,213 (“Moller”)

Inv. No. 337-TA-1300
21. U.S. Patent No. 4,972,130 (“Rossi”)
1. International Patent Publication No. WO 2010/111433 (“Smith”)
2. International Patent Publication No. WO 2012/055968 (“Hoyerby”)
3. Chinese Patent Publication No. CN102931893A (“Nikesen”)
1. A Two-Way Inductive Power Interface for Single Loads, Madawala &

Thrimawithana, 2010 IEEE International Conference on Industrial
Technology, 673-678 (2010).
2. A High-Speed H-Bridge Circuit Based on GaN HFETs and Custom

Resonant Gate Drivers, Wang et al., 2009 IEEE Energy Conversion
Congress and Exposition, 973-978 (2009).
Inv. No. 337-TA-1300


22-04-04 ITC-1300 Apple Answer To Complaint

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22-04-04 ITC-1300 Apple Answer To Complaint

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UNITED STATES INTERNATIONAL TRADE COMMISSION

Before the Honorable MaryJoan McNamara

CERTAIN MOBILE PHONES, TABLET

RESPONDENT APPLE INC.’S RESPONSE TO THE COMPLAINT OF

RESPONDENT COUNSEL FOR APPLE INC.

Apple Inc. Benjamin C. Elacqua

Inv. No. 337-TA-1300

Inv. No. 337-TA-1300

Pursuant to 19 C.F.R. § 210.13, Respondent Apple Inc. (“Apple” or “Respondent”) by

of 1930 as Amended (the “Complaint”), filed by Ericsson Inc. and Telefonaktiebolaget LM

as a result of additional information discovered subsequent to filing this Response, or to the

extent Ericsson modifies its Complaint or contentions.

1. To the extent that Paragraph 1 contains conclusions of law, no response is

’621 patent, the ’770 patent, or the ’400 patent.

2. To the extent that Paragraph 2 contains conclusions of law, no response is

4. To the extent that Paragraph 4 contains conclusions of law, no response is

allegations contained in Paragraph 4 and, on that basis, denies them.

5. To the extent that Paragraph 5 contains conclusions of law, no response is

limitation, the relief requested in Paragraph 5.

Complainants in this investigation.

7. On information and belief, Apple admits that Ericsson Inc. is a corporation

business at 6300 Legacy Drive, Plano, Texas 75024.

8. On information and belief, Apple admits that LM Ericsson is a corporation

Paragraph 8 and, on that basis, denies them.

the allegations contained in Paragraph 9 and, on that basis, denies them.

the allegations contained in Paragraph 10 and, on that basis, denies them.

the allegations contained in Paragraph 11 and, on that basis, denies them.

III. PROPOSED RESPONDENT APPLE

characterizations in Paragraph 14.

IV. THE ACCUSED PRODUCTS AND TECHNOLOGY AT ISSUE

16. To the extent that Paragraph 16 contains conclusions of law, no response is

characterizations contained in Paragraph 16 and, on that basis, denies them.

V. THE ASSERTED PATENTS AND NON-TECHNICAL DESCRIPTIONS

A. U.S. Patent 7,151,430

Identification and Ownership of the ’430 Patent

contained in Paragraph 17 and, on that basis, denies them.

contained in Paragraph 18 and, on that basis, denies them.

19. To the extent that Paragraph 19 contains conclusions of law, no response is

Paragraph 19 and, on that basis, denies them.

20. Apple admits that Appendix A purports to be an electronic version of a certified

and characterizations in Paragraph 20.

Non-Technical Description of the ’430 Patent

21. To the extent that Paragraph 21 contains conclusions of law, no response is

inventive, or nonobvious. Apple is without knowledge or information sufficient to form a belief

22. To the extent that Paragraph 22 contains conclusions of law, no response is

23. To the extent that Paragraph 23 contains conclusions of law, no response is

on that basis, denies them.

B. U.S. Patent Nos. 9,509,273 and 9,853,621

statements contained in Paragraph 26 and, on that basis, denies them.

27. To the extent that Paragraph 27 contains conclusions of law, no response is

28. To the extent that Paragraph 28 contains conclusions of law, no response is

29. To the extent that Paragraph 29 contains conclusions of law, no response is

currently in full force and effect until July 23, 2032.

30. To the extent that Paragraph 30 contains conclusions of law, no response is

currently in full force and effect until July 23, 2032.

Paragraph 31 and, on that basis, denies them.

32. Apple admits that Appendix B purports to be an electronic version of a certified

characterizations in Paragraph 32.

Non-Technical Description of the ’273 Patent and the ’621 Patent

allegations contained in Paragraph 33 and, on that basis, denies them.

34. To the extent that Paragraph 34 contains conclusions of law, no response is

contained in Paragraph 34 and, on that basis, denies them.

35. To the extent that Paragraph 35 contains conclusions of law, no response is