PA Advisors, LLC v. Google Inc. et al

Filing 68

RESPONSE to #39 Answer to Complaint,, Counterclaim, of Google Inc. by PA Advisors, LLC. (LaValle, Amy)

PA Advisors, LLC v. Google Inc. et al

Doc. 68

Case 2:07-cv-00480-TJW

Document 68

Filed 01/14/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PA ADVISORS, LLC Plaintiff, No. 2:07-cv-480-TJW v. JURY TRIAL DEMANDED GOOGLE INC., ET AL. Defendants. PLAINTIFF'S REPLY TO DEFENDANT GOOGLE INC.'S COUNTERCLAIMS Plaintiff PA Advisors, LLC ("PA Advisors") replies to the counterclaims of Defendant Google Inc. ("Google") by corresponding paragraph number as follows: 1. 2. admitted. 3. 4. 5. Admitted. Admitted. Paragraph 5 purports to incorporate by reference the allegations in paragraphs 1 Admitted. Denied that PA Advisors, LLC is an "LLP" or a "corporation." Otherwise

through 36 of Google's answer and defenses and paragraphs 1 through 4 of its counterclaims and is, therefore, improper and incapable of being admitted or denied. Subject to the foregoing, PA Advisors incorporates its responses to paragraphs 1 through 4 above and denies the merits of Google's allegations and defenses set forth in its answer. 6. 7. 8. Admitted. Admitted. Denied.

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Dockets.Justia.com

Case 2:07-cv-00480-TJW

Document 68

Filed 01/14/2008

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9.

Paragraph 9 purports to incorporate by reference the allegations in paragraphs 1

through 36 of Google's answer and defenses and paragraphs 1 through 8 of its counterclaims and is, therefore, improper and incapable of being admitted or denied. Subject to the foregoing, PA Advisors incorporates its responses to paragraphs 1 through 8 above and denies the merits of Google's allegations and defenses set forth in its answer. 10. 11. Denied. Denied.

To the extent necessary, Plaintiff denies that Google is entitled to the relief requested in its prayer for relief. In addition, to the extent necessary, Plaintiff denies any allegation in the counterclaims not specifically admitted above, and Plaintiff re-alleges infringement, enforceability, validity and its damages, and denies any allegations in the counterclaims adverse to same. PRAYER FOR RELIEF PA Advisors respectfully requests that this Court enter judgment denying and dismissing Google's counterclaims, and that the Court enter judgment in favor of Plaintiff as requested in Plaintiff's complaint, as amended or supplemented.

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Case 2:07-cv-00480-TJW

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Dated: January 14, 2008

Respectfully submitted, PA ADVISORS, LLC By: /s/ David M. Pridham Eric M. Albritton Texas State Bar No. 00790215 ALBRITTON LAW FIRM P.O. Box 2659 Longview, Texas 75606 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] David M. Pridham R.I. State Bar No. 6625 IP NAVIGATION GROUP, LLC 207 C North Washington Avenue Marshall, Texas 75670 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Amy E. LaValle Texas State Bar No. 24040529 THE LAVALLE LAW FIRM 3811 Turtle Creek Boulevard Suite 1620 Dallas, Texas 75219 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Of Counsel: Joseph Diamante JENNER & BLOCK LLP 919 Third Avenue, 37th Floor New York, New York 10022-3908 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] ATTORNEYS FOR PLAINTIFF PA ADVISORS, LLC

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Case 2:07-cv-00480-TJW

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CERTIFICATE OF SERVICE I hereby certify that the counsel of record who are deemed to have consented to electronic service are being served today with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3). Any other counsel of record will be served by electronic mail, facsimile transmission and/or first class mail on this same date.

Dated: January 14, 2008

/s/ Amy E. LaValle

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