to another’s infringement.' In that situation, it is not unfair to expect the defendant to plead contrary facts demonstrating that its actions did not involve such indirect infringement. Likewise, a counterclaim of invalidity must be measured against the Twombly standard. That is consonant with the clear directive from the Federal Circuit that Rule 18 only governs allegations concerning direct infringement. A counterclaim that “asserts no factual allegation on which th[e] Court or Plaintiff can pin the invalidity of any claim of the patent” is insufficient. PPS Data, LLC v. Allscripts Healthcare Solutions, Inc., No. 3:11-cv-273, 2012 WL 243346, at *4 (M.D.Fla. Jan. 25, 2012). See also Armstrong Pump, Inc. v. Hartman, No. 10-CV-4465, 2012 WL 1029645, at *2 (W.D.N.Y. Mar. 26, 2012) (<HOLDING>); Memory Control Enterprise, LLC v.
holding that applicable federal patent law made patents personal and unassignable without consent of the licensor holding that the complaint placed the defendant on notice when it alleged ownership of the asserted patent named the individual defendants cited the patents that are allegedly infringed described the means by which the defendants allegedly infringed the patents and pointed to specific sections of the patent law invoked holding that counterclaims for patent invalidity were insufficient under either the form 18 or twombly standard where the counterclaims conclusorily alleged that every claim in each of three patents failed to meet one or multiple unspecified conditions for patentability and were devoid of any facts that would suggest which deficiencyies applied to which patents or claims and therefore did not give fair notice  of the basis for the counterclaims recognizing that in patent infringement eases a finding of noninfringement prevents a court from reaching an affirmative defense asserting the patents invalidity because the validity issue becomes immaterial to the disposition of the case and that any determination of the patents validity by the district court in such a case should be vacated holding that when two patents issued from continuationinpart appliea tions derived from one original application the prosecution history of a claim limitation in the first patent to issue was properly applied to the same claim limitation in the second patent to issue