The filing relates to Qualcomm's alleged unauthorised use of six Nokia implementation patents in its MediaFLO and Brew businesses.
Nokia pointed out that Qualcomm has sought injunctions against the mobile firm in previous litigation, forcing it to seek damages and "injunctive relief" .
"Nokia has a strong history of innovation in intellectual property broadcast television and mobile download environments predating Qualcomm's activities," said Tero Ojanpera, chief technology officer at Nokia.
"This is another example where Qualcomm has effectively copied Nokia's innovations. We believe that, for MediaFLO to evolve and for Brew to remain viable, Qualcomm needs access to these and many other patented Nokia inventions. "
Nokia argued that its patents are at the "core of MediaFLO and Brew technologies", for example in ensuring the broadcast quality of service within MediaFLO and in enabling the download of applications with Brew.
The firm added that it has recently declared another set of patents to the Telecommunication Industry Association as essential for the FLO air interface used in MediaFLO.
Nokia added that it will "continue to vigorously defend itself" against the infringement and unauthorised use of its intellectual property.
Nokia's patent counter assertions are part of its response to the Qualcomm lawsuit filed in the Eastern District of Texas on 2 April 2007.
In that lawsuit Qualcomm's three patents-in-suit allegedly involve certain types of mobile software download and execution environments.
Nokia is confident that the Qualcomm patents are invalid, for example, based on the alleged inventions having been patented or published by other companies, including Nokia, before Qualcomm.
In addition, Nokia believes that its products do not infringe any of the patents.
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