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Case 1 :04-cv-00874—GI\/IS Document 56 Filed 10/19/2005 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE A
TELCORDIA TECHNOLOGIES, INC.,
Plaintyf
Counterclaim—Defendmzt,
vs. Case No. 04—C\/-874 GMS
IURY TRIAL DEMANDED
ALCATEL USA, INC.,
Deferzdarzt,
C0u11te2·clai1n—Plaint@€
ALCATEL USA’S REPLY TO
TELCORDIA’S COUNTERCLAIM `
Alcatel USA, Inc. ("Alcatel") hereby requests a trial by jury of all issues so triable
and responds to each of the numbered paragraphs of Telcordia’s Counterclaim, set forth
in Telcordia’s Reply to Alcatel USA, Inc.’s Amended [sic] Counterclaims and Demand
for Jury Trial, as follows:
PARTIES
l. Alcatel lacks knowledge or information sufficient to form a belief as to the
truth or correctness of the allegations set forth in Paragraph 84 of Telcordia’s
Counterclaim and therefore denies the allegations.
2. Alcatel denies that its Counterclaims were "Amended." Alcatel admits
that it is a corporation organized and existing under the laws of Delaware, having a
business address at 3400 W. Plano Parkway, Plano, Texas but states that its zip code is
75075, not 7075.

Case 1:04-cv-00874—G|\/IS Document 56 Filed 10/19/2005 Page 2 of 4
JURISDICTION AND VENUE p
3. Alcatel admits that Telcordia’s Counterclaim contains averments for
declaratory judgment of non-inhingement and invalidity of United States Patent No.
6,247,052.
4. Alcatel admits that 28 U.S.C. §§ 1331, 1338, 1367, 2201, and 2202 grant
this Court subject matter jurisdiction over civil actions arising under the patent laws of
the United States.
5. Alcatel denies that its Counterclaims were "Amended." For purposes of
this litigation only, Alcatel does not contest that this Court has personal jurisdiction over
Alcatel,
6. For purposes of this litigation only, Alcatel does not contest that venue is
proper under 28 U.S.C. § 1391(b), (c) and § 1400(b). A
COUNT I: DECLARATION OF
NON-INFRINGEMENT AND INVALIDITY
7. Paragraph 90 of Te1cordia’s Counterclaim realleges and incorporates by
reference Paragraphs 83-89 of the Counterclaim. Thus, Alcatel answers Paragraph 90 in
the same manner it answered Paragraphs 83-89.
8. Alcatel admits the allegations set forth in Paragraph 91 of Te1cordia’s
Counterclaim.
9. Alcatel denies the allegations set forth in Paragraph 92 of Telcordia’s
Counterclaim.
10. Alcatel denies the allegations set forth in Paragraph 93 of Telcordia’s
Counterclaim.
11. Alcatel denies the allegations set forth in Paragraph 94 of Telcordia’s
Counterclaim.
2

Case 1 :04-cv-00874—GI\/IS Document 56 Filed 10/19/2005 Page 3 of 4
PRAYER FOR RELIEF
WHEREFORE, Alcatel respectfully requests that judgment be entered in its favor ‘
on Telcordia’s Counterclaim and that Telcordia be denied any relief based on its
Counterclaim, including the relief requested in Paragraphs A through D of its Prayer for
Relief Regarding Telcordia’s Counterclaim.
DEMAND FOR IU RY TRIAL
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Alcatel requests a
trial by jury of all issues so triable.
Dated: October 19, 2005 Respectfully submitted:
Josy ilggersoll (I.D. N0. 1088)
Adam W. Poff (I.D. N0. 3990)
Younc CoNAwAY STARGATT & TAYLoR, LLP
The Brandywine Building
1000 West Street
Wilmington, DE 19801
Tel. (302) 571-6672
[email protected]
Attorneys for Defendant / Counterclaim
Plairztyf Alcatel USA, [nc.
OF COUNSEL:
Stuart J. Sinder
Mark A. Hannemann
Michelle Carniaux
Clement J. Naples
KBNYoN & KENYoN
One Broadway
New York, NY 10004
Tel. (212) 425-7200
3

Case 1:04-cv-00874—G|\/IS Document 56 Filed 10/19/2005 Page 4 of 4
CERTIFICATE OF SERVICE
I, Adam W. Poff, Esquire hereby certify that on October 19, 2005, I caused to be
electronically filed a true and correct copy of the foregoing document with the Clerk of the Court
using CM/ECF, which will send notification that such filing is available for viewing and
downloading to the following counsel of record:
Steven J. Balick, Esquire
Ashby & Geddes
222 Delaware Avenue
Wilmington, DE 19801
I further certify that on October 19, 2005, I caused a copy of the foregoing document to
be served by hand delivery on the above—listed counsel of record and on the following non-
registered participants in the manner indicated:
BY E-MAIL
Richard L. Rainey, Esquire
Finnegan, Henderson, Farabow,
Garrett & Dunner, L.L.P.
901 New York Avenue, NW
Washington, DC 20001
YOUNG CONAWAY ST; QGATT & TAYLOR, LLP
Adam W. Poff (No. 3990)
The Brandywine Building
1000 West Street, 17th Floor
Wilmington, Delaware 19801
(302) 571-6600
[email protected]
Attorneys for Defendants
DB0l:l5924l3.l