Parallel Networks, LLC v. Adidas America, Inc. et al

Filing 282

Defendant New Balance Athletic Shoe, Inc.'s ANSWER to #1 Complaint,,,,,,,, COUNTERCLAIM against Parallel Networks, LLC by New Balance Athletic Shoe, Inc..(Stevens, Scott)

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Parallel Networks, LLC v. Adidas America, Inc. et al Doc. 282 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION PARALLEL NETWORKS, LLC Plaintiffs, v. ADIDAS AMERICA, INC.; et al. Defendant. DEFENDANT NEW BALANCE ATHLETIC SHOE, INC.'S ANSWER TO PLAINTIFF'S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT Defendant New Balance Athletic Shoe, Inc. ("New Balance") answers the Original Complaint for Patent Infringement of Parallel Networks, LLC ("Parallel Networks") as follows: THE PARTIES 1. Defendant New Balance is without knowledge or information sufficient to form a CIVIL ACTION NO. 6:10-cv-00491 JURY TRIAL DEMANDED belief as to the truth of these allegations and therefore denies them. 2. The allegations of paragraph 2 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 3. The allegations of paragraph 3 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 1 Dockets.Justia.com 4. The allegations of paragraph 4 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 5. The allegations of paragraph 5 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 6. The allegations of paragraph 6 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 7. The allegations of paragraph 7 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 8. The allegations of paragraph 8 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 9. The allegations of paragraph 9 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. 2 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 10. The allegations of paragraph 10 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 11. The allegations of paragraph 11 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 12. The allegations of paragraph 12 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 13. The allegations of paragraph 13 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 14. The allegations of paragraph 14 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 3 15. The allegations of paragraph 15 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 16. The allegations of paragraph 16 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 17. The allegations of paragraph 17 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 18. The allegations of paragraph 18 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 19. The allegations of paragraph 19 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 20. The allegations of paragraph 20 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. 4 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 21. The allegations of paragraph 21 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 22. The allegations of paragraph 22 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 23. The allegations of paragraph 23 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 24. The allegations of paragraph 24 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 25. The allegations of paragraph 25 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 5 26. The allegations of paragraph 26 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 27. The allegations of paragraph 27 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 28. The allegations of paragraph 28 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 29. The allegations of paragraph 29 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 30. The allegations of paragraph 30 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 31. The allegations of paragraph 31 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. 6 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 32. The allegations of paragraph 32 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 33. The allegations of paragraph 33 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 34. The allegations of paragraph 34 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 35. The allegations of paragraph 35 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 36. The allegations of paragraph 36 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 7 37. The allegations of paragraph 37 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 38. The allegations of paragraph 38 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 39. The allegations of paragraph 39 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 40. The allegations of paragraph 40 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 41. The allegations of paragraph 41 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 42. The allegations of paragraph 42 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. 8 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 43. The allegations of paragraph 43 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 44. The allegations of paragraph 44 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 45. The allegations of paragraph 45 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 46. The allegations of paragraph 46 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 47. The allegations of paragraph 47 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 9 48. The allegations of paragraph 48 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 49. The allegations of paragraph 49 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 50. The allegations of paragraph 50 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 51. 52. Admitted. The allegations of paragraph 52 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 53. The allegations of paragraph 53 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 54. The allegations of paragraph 54 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. 10 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 55. The allegations of paragraph 55 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 56. The allegations of paragraph 56 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 57. The allegations of paragraph 57 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 58. The allegations of paragraph 58 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 59. The allegations of paragraph 59 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 11 60. The allegations of paragraph 60 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 61. The allegations of paragraph 61 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. JURISDICTION AND VENUE 62. Defendant New Balance admits that this action purports to arise under the patent laws of the United States, Title 35 of the United States Code. Defendant New Balance admits that this Court has subject matter jurisdiction pursuant to 28 U.S.C. 1331 and 1338(a), and that New Balance is subject to this Court's specific and general personal jurisdiction, but denies that it is committing or has committed any act of infringement alleged in the Plaintiff's Original Complaint for Patent Infringement. Defendant New Balance admits that it is subject to this Court's general jurisdiction and that it does business in this forum, and derives revenue from goods and services provided to persons or entities in Texas. Defendant New Balance denies the remaining allegations of this paragraph, as they relate to Defendant New Balance. As to the other Defendants, New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 63. Defendant New Balance denies that venue is proper under 28 U.S.C. 1391(b), 1391(c) and 1400(b). Defendant New Balance admits that it is subject to personal jurisdiction in this District, but denies that it is committing or has committed any act of infringement alleged in the Plaintiff's Original Complaint for Patent Infringement. Defendant New Balance denies the 12 remaining allegations of this paragraph, as they relate to Defendant New Balance. As to the other defendants, Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. COUNT I INFRINGEMENT OF U.S. PATENT NO. 6,446,111 64. Defendant New Balance admits that the face of U.S. Patent No. 6,446,111 indicates that it is entitled "Method and Apparatus for Client-Server Communications Using a Limited Capability Client Over a Low Speed Communications Network" and that it issued on September 3, 2002. 65. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations, and therefore denies them. 66. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations, and therefore denies them. 67. The allegations of paragraph 67 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 68. The allegations of paragraph 68 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 69. The allegations of paragraph 69 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. 13 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 70. The allegations of paragraph 70 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 71. The allegations of paragraph 71 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 72. The allegations of paragraph 72 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 73. The allegations of paragraph 73 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 74. The allegations of paragraph 74 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 14 75. The allegations of paragraph 75 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 76. The allegations of paragraph 76 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 77. The allegations of paragraph 77 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 78. The allegations of paragraph 78 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 79. The allegations of paragraph 79 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 80. The allegations of paragraph 80 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. 15 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 81. The allegations of paragraph 81 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 82. The allegations of paragraph 82 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 83. The allegations of paragraph 83 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 84. The allegations of paragraph 84 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 85. The allegations of paragraph 85 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 16 86. The allegations of paragraph 86 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 87. The allegations of paragraph 87 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 88. The allegations of paragraph 88 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 89. The allegations of paragraph 89 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 90. The allegations of paragraph 90 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 91. The allegations of paragraph 91 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. 17 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 92. The allegations of paragraph 92 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 93. The allegations of paragraph 93 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 94. The allegations of paragraph 94 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 95. The allegations of paragraph 95 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 96. The allegations of paragraph 96 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 18 97. The allegations of paragraph 97 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 98. The allegations of paragraph 98 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 99. The allegations of paragraph 99 are not directed towards Defendant New Balance, Defendant New Balance is without knowledge or and therefore, no answer is required. information sufficient to form a belief as to the truth of these allegations and therefore denies them. 100. The allegations of paragraph 100 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 101. The allegations of paragraph 101 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 102. The allegations of paragraph 102 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or 19 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 103. The allegations of paragraph 103 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 104. The allegations of paragraph 104 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 105. The allegations of paragraph 105 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 106. The allegations of paragraph 106 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 107. The allegations of paragraph 107 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 20 108. The allegations of paragraph 108 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 109. The allegations of paragraph 109 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 110. The allegations of paragraph 110 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 111. The allegations of paragraph 111 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 112. The allegations of paragraph 112 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 113. The allegations of paragraph 113 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or 21 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 114. The allegations of paragraph 114 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 115. The allegations of paragraph 115 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 116. The allegations of paragraph 116 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 117. The allegations of paragraph 117 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 118. The allegations of paragraph 118 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 22 119. The allegations of paragraph 119 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 120. The allegations of paragraph 120 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 121. The allegations of paragraph 121 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 122. The allegations of paragraph 122 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 123. The allegations of paragraph 123 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 124. The allegations of paragraph 124 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or 23 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 125. The allegations of paragraph 125 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 126. The allegations of paragraph 126 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 127. The allegations of paragraph 127 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 128. The allegations of paragraph 128 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 129. The allegations of paragraph 129 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 24 130. The allegations of paragraph 130 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 131. The allegations of paragraph 131 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 132. The allegations of paragraph 132 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 133. The allegations of paragraph 133 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 134. The allegations of paragraph 134 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 135. The allegations of paragraph 135 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or 25 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 136. The allegations of paragraph 136 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 137. The allegations of paragraph 137 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 138. The allegations of paragraph 138 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 139. The allegations of paragraph 139 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 140. The allegations of paragraph 140 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 26 141. The allegations of paragraph 141 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 142. The allegations of paragraph 142 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 143. The allegations of paragraph 143 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 144. The allegations of paragraph 144 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 145. The allegations of paragraph 145 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 146. The allegations of paragraph 146 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or 27 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 147. The allegations of paragraph 147 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 148. The allegations of paragraph 148 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 149. The allegations of paragraph 149 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 150. The allegations of paragraph 150 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 151. The allegations of paragraph 151 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 28 152. The allegations of paragraph 152 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 153. The allegations of paragraph 153 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 154. The allegations of paragraph 154 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 155. The allegations of paragraph 155 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 156. The allegations of paragraph 156 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 157. The allegations of paragraph 157 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or 29 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 158. The allegations of paragraph 158 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 159. The allegations of paragraph 159 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 160. The allegations of paragraph 160 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 161. The allegations of paragraph 161 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 162. The allegations of paragraph 162 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 30 163. The allegations of paragraph 163 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 164. The allegations of paragraph 164 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 165. The allegations of paragraph 165 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 166. The allegations of paragraph 166 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 167. The allegations of paragraph 167 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 168. The allegations of paragraph 168 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or 31 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 169. The allegations of paragraph 169 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 170. The allegations of paragraph 170 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 171. The allegations of paragraph 171 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 172. The allegations of paragraph 172 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 173. The allegations of paragraph 173 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 32 174. The allegations of paragraph 174 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 175. The allegations of paragraph 175 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 176. The allegations of paragraph 176 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 177. The allegations of paragraph 177 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 178. The allegations of paragraph 178 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 179. The allegations of paragraph 179 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or 33 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 180. The allegations of paragraph 180 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 181. The allegations of paragraph 181 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 182. The allegations of paragraph 182 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 183. The allegations of paragraph 183 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 184. The allegations of paragraph 184 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 34 185. The allegations of paragraph 185 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 186. The allegations of paragraph 186 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 187. The allegations of paragraph 187 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 188. The allegations of paragraph 188 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 189. The allegations of paragraph 189 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 190. The allegations of paragraph 190 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or 35 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 191. The allegations of paragraph 191 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 192. The allegations of paragraph 192 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 193. The allegations of paragraph 193 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 194. The allegations of paragraph 194 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 195. The allegations of paragraph 195 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 36 196. The allegations of paragraph 196 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 197. The allegations of paragraph 197 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 198. The allegations of paragraph 198 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 199. The allegations of paragraph 199 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 200. The allegations of paragraph 200 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 201. The allegations of paragraph 201 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or 37 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 202. The allegations of paragraph 202 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 203. The allegations of paragraph 203 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 204. The allegations of paragraph 204 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 205. The allegations of paragraph 205 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 206. The allegations of paragraph 206 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 38 207. The allegations of paragraph 207 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 208. The allegations of paragraph 208 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 209. The allegations of paragraph 209 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 210. The allegations of paragraph 210 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 211. The allegations of paragraph 211 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 212. The allegations of paragraph 212 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or 39 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 213. The allegations of paragraph 213 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 214. The allegations of paragraph 214 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 215. The allegations of paragraph 215 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 216. The allegations of paragraph 216 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 217. The allegations of paragraph 217 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 40 218. The allegations of paragraph 218 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 219. The allegations of paragraph 219 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 220. The allegations of paragraph 220 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 221. The allegations of paragraph 221 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 222. The allegations of paragraph 222 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 223. The allegations of paragraph 223 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or 41 information sufficient to form a belief as to the truth of these allegations and therefore denies them. 224. The allegations of paragraph 224 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 225. The allegations of paragraph 225 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 226. The allegations of paragraph 226 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 227. The allegations of paragraph 227 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 228. The allegations of paragraph 228 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 42 229. The allegations of paragraph 229 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 230. The allegations of paragraph 230 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 231. The allegations of paragraph 231 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 232. The allegations of paragraph 232 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 233. The allegations of paragraph 233 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New Balance is without knowledge or information sufficient to form a belief as to the truth of these allegations and therefore denies them. 234. The allegations of paragraph 234 are not directed towards Defendant New Balance, and therefore, no answer is required. Defendant New B

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