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

Filing 356

Victoria's Secret Direct Brand Management, LLC's ANSWER to #1 Complaint,,,,,,, Affirmative Defenses and, COUNTERCLAIM against Parallel Networks, LLC by Victoria's Secret Direct Brand Management, LLC.(Ainsworth, Charles)

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

Doc. 356

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION PARALLEL NETWORKS, LLC, Plaintiff, v. ADIDAS AMERICA, INC.; ADIDAS INTERACTIVE, INC.; AEROPOSTALE, INC.; AMERICAN GIRL, LLC; AMERICAN SUZUKI MOTOR CORPORATION; ANDERSEN CORPORATION; ANDERSEN WINDOWS, INC.; ASICS AMERICA CORPORATION; AT&T INC.; BBY SOLUTIONS, INC.; BERGDORFGOODMAN.COM, LLC; BESTBUY.COM, LLC; BLOOMINGDALE'S, INC.; BRIGGS & STRATTON CORPORATION; BRIGGS & STRATTON POWER PRODUCTS GROUP, LLC; BRUNSWICK BILLIARDS, INC.; BRUNSWICK CORPORATION; CHICO'S RETAIL SERVICES, INC.; CITIZEN WATCH COMPANY OF AMERICA, INC.; DILLARD'S, INC.; EASTMAN KODAK COMPANY; GENERAL MOTORS LLC; THE GILLETTE COMPANY; THE GOODYEAR TIRE & RUBBER COMPANY; H-D MICHIGAN, INC.; HARLEY-DAVIDSON, INC.; HASBRO, INC.; HAYNEEDLE, INC.; HERMAN MILLER, INC.; HSN INTERACTIVE LLC; HSN LP; THE J. JILL GROUP, INC.; JILL ACQUISITION LLC; JONES INVESTMENT COMPANY, INC.; JONES RETAIL CORPORATION; KODAK IMAGING NETWORK, INC.; KOHL'S DEPARTMENT STORES, INC.; LG ELECTRONICS USA, INC.; MACY'S WEST STORES, INC.; MACYS.COM, INC.; MATTEL, INC.; MITSUBISHI MOTOR SALES OF AMERICA, INC.; MITSUBISHI MOTORS NORTH AMERICA, INC.; 1 Case No. 6:10-cv-00491-LED JURY TRIAL DEMANDED

Dockets.Justia.com

MOTOROLA, INC.; MOTOROLA TRADEMARK HOLDINGS, LLC; NAUTICA APPAREL, INC.; NAUTICA RETAIL USA, INC.; NAVISTAR, INC.; NEW BALANCE ATHLETIC SHOE, INC.; NISSAN NORTH AMERICA, INC.; PRL USA HOLDINGS, INC.; THE PROCTER & GAMBLE COMPANY; RALPH LAUREN MEDIA LLC; RUSSELL BRANDS, LLC; SUBARU OF AMERICA, INC.; SUNGLASS HUT TRADING, LLC; VICTORIA'S SECRET; WOLVERINE WORLD WIDE, INC.; and WOMEN'S APPAREL GROUP, LLC d/b/a BOSTON APPAREL GROUP, LLC, Defendants. DEFENDANT VICTORIA'S SECRET DIRECT BRAND MANAGEMENT, LLC'S ANSWER, AFFIRMATIVE DEFENSES, AND COUNTERCLAIMS TO PARALLEL NETWORKS, LLC'S ORIGINAL COMPLAINT Defendant Victoria's Secret Direct Brand Management, LLC ("VSDBM"), by its undersigned counsel, hereby files its Answer, Affirmative Defenses, and Counterclaims to the Complaint of Parallel Networks, LLC ("Parallel Networks"), denying all allegations of the Complaint, unless specifically admitted, and respectfully states: ANSWER PARTIES 1. In response to Paragraph 1 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 2. In response to Paragraph 2 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 2

3.

In response to Paragraph 3 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 4. In response to Paragraph 4 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 5. In response to Paragraph 5 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 6. In response to Paragraph 6 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 7. In response to Paragraph 7 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 8. In response to Paragraph 8 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 9. In response to Paragraph 9 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

3

10.

In response to Paragraph 10 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 11. In response to Paragraph 11 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 12. In response to Paragraph 12 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 13. In response to Paragraph 13 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 14. In response to Paragraph 14 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 15. In response to Paragraph 15 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 16. In response to Paragraph 16 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

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17.

In response to Paragraph 17 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 18. In response to Paragraph 18 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 19. In response to Paragraph 19 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 20. In response to Paragraph 20 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 21. In response to Paragraph 21 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 22. In response to Paragraph 22 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 23. In response to Paragraph 23 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

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24.

In response to Paragraph 24 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 25. In response to Paragraph 25 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 26. In response to Paragraph 26 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 27. In response to Paragraph 27 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 28. In response to Paragraph 28 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 29. In response to Paragraph 29 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 30. In response to Paragraph 30 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

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31.

In response to Paragraph 31 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 32. In response to Paragraph 32 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 33. In response to Paragraph 33 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 34. In response to Paragraph 34 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 35. In response to Paragraph 35 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 36. In response to Paragraph 36 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 37. In response to Paragraph 37 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

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38.

In response to Paragraph 38 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 39. In response to Paragraph 39 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 40. In response to Paragraph 40 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 41. In response to Paragraph 41 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 42. In response to Paragraph 42 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 43. In response to Paragraph 43 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 44. In response to Paragraph 44 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

8

45.

In response to Paragraph 45 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 46. In response to Paragraph 46 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 47. In response to Paragraph 47 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 48. In response to Paragraph 48 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 49. In response to Paragraph 49 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 50. In response to Paragraph 50 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 51. In response to Paragraph 51 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

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52.

In response to Paragraph 52 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 53. In response to Paragraph 53 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 54. In response to Paragraph 54 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 55. In response to Paragraph 55 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 56. In response to Paragraph 56 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 57. In response to Paragraph 57 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 58. In response to Paragraph 58 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

10

59.

In response to Paragraph 59 of the Complaint, VSDBM, as the entity

substituted for the non-existent original defendant "Victoria's Secret," admits that it is a corporation with a place of business in Columbus, Ohio. 60. In response to Paragraph 60 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 61. In response to Paragraph 61 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. JURISDICTION AND VENUE 62. In response to Paragraph 62 of the Complaint, VSDBM admits that

Parallel Networks purports to bring this action under Title 35 of the United States Code. VSDBM admits that this Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a), however, VSDBM expressly denies any liability thereunder. To the extent the allegations are directed to VSDBM, VSDBM admits that it is subject to specific and general personal jurisdiction in this Court. To the extent the allegations are directed to defendants other than VSDBM, VSDBM states that it lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. VSDBM denies the remaining allegations of Paragraph 62, including the allegation that VSDBM has engaged in making, using, or induced or contributed to the using of the accused systems identified in the Complaint. 63. In response to Paragraph 63, for purposes of this lawsuit only, VSDBM

does not contest that venue is proper in this Court under 28 U.S.C. §§ 1391(b), 1391(c)

11

and 1400(b), although VSDBM maintains that there are more convenient fora in which to proceed with this action. To the extent the allegations are directed to VSDBM, VSDBM admits that it is subject to personal jurisdiction in this Court. To the extent the allegations are directed to defendants other than VSDBM, VSDBM states that it lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. VSDBM denies the remaining allegations of Paragraph 63, including the allegation that VSDBM has committed at least a portion of the infringement at issue in this case and that VSDBM has engaged in, contributed to, and induced the infringing acts identified in the Complaint. COUNT I ALLEGED INFRINGEMENT OF U.S. PATENT NO. 6,446,111 64. In response to Paragraph 64 of the Complaint, VSDBM admits that the

face of United States Patent No. 6,446,111 (the "`111 patent") indicates that it is titled "Method and Apparatus for Client-Server Communication Using a Limited Capability Client Over a Low-Speed Communications Link" and that it issued on September 3, 2002. 65. In response to Paragraph 65 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 66. 67. VSDBM denies the allegations of Paragraph 66 of the Complaint. In response to Paragraph 67 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

12

68.

In response to Paragraph 68 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 69. In response to Paragraph 69 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 70. In response to Paragraph 70 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 71. In response to Paragraph 71 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 72. In response to Paragraph 72 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 73. In response to Paragraph 73 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 74. In response to Paragraph 74 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

13

75.

In response to Paragraph 75 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 76. In response to Paragraph 76 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 77. In response to Paragraph 77 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 78. In response to Paragraph 78 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 79. In response to Paragraph 79 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 80. In response to Paragraph 80 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 81. In response to Paragraph 81 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

14

82.

In response to Paragraph 82 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 83. In response to Paragraph 83 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 84. In response to Paragraph 84 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 85. In response to Paragraph 85 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 86. In response to Paragraph 86 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 87. In response to Paragraph 87 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 88. In response to Paragraph 88 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

15

89.

In response to Paragraph 89 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 90. In response to Paragraph 90 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 91. In response to Paragraph 91 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 92. In response to Paragraph 92 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 93. In response to Paragraph 93 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 94. In response to Paragraph 94 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 95. In response to Paragraph 95 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

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96.

In response to Paragraph 96 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 97. In response to Paragraph 97 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 98. In response to Paragraph 98 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 99. In response to Paragraph 99 of the Complaint, VSDBM states that it lacks

knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 100. In response to Paragraph 100 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 101. In response to Paragraph 101 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 102. In response to Paragraph 102 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

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103.

In response to Paragraph 103 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 104. In response to Paragraph 104 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 105. In response to Paragraph 105 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 106. In response to Paragraph 106 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 107. In response to Paragraph 107 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 108. In response to Paragraph 108 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 109. In response to Paragraph 109 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

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110.

In response to Paragraph 110 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 111. In response to Paragraph 111 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 112. In response to Paragraph 112 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 113. In response to Paragraph 113 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 114. In response to Paragraph 114 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 115. In response to Paragraph 115 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 116. In response to Paragraph 116 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

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117.

In response to Paragraph 117 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 118. In response to Paragraph 118 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 119. In response to Paragraph 119 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 120. In response to Paragraph 120 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 121. In response to Paragraph 121 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 122. In response to Paragraph 122 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 123. In response to Paragraph 123 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

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124.

In response to Paragraph 124 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 125. In response to Paragraph 125 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 126. In response to Paragraph 126 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 127. In response to Paragraph 127 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 128. In response to Paragraph 128 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 129. In response to Paragraph 129 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 130. In response to Paragraph 130 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

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131.

In response to Paragraph 131 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 132. In response to Paragraph 132 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 133. In response to Paragraph 133 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 134. In response to Paragraph 134 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 135. In response to Paragraph 135 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 136. In response to Paragraph 136 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 137. In response to Paragraph 137 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

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138.

In response to Paragraph 138 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 139. In response to Paragraph 139 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 140. In response to Paragraph 140 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 141. In response to Paragraph 141 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 142. In response to Paragraph 142 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 143. In response to Paragraph 143 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 144. In response to Paragraph 144 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

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145.

In response to Paragraph 145 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 146. In response to Paragraph 146 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 147. In response to Paragraph 147 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 148. In response to Paragraph 148 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 149. In response to Paragraph 149 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 150. In response to Paragraph 150 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 151. In response to Paragraph 151 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

24

152.

In response to Paragraph 152 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 153. In response to Paragraph 153 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 154. In response to Paragraph 154 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 155. In response to Paragraph 155 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 156. In response to Paragraph 156 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 157. In response to Paragraph 157 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 158. In response to Paragraph 158 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

25

159.

In response to Paragraph 159 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 160. In response to Paragraph 160 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 161. In response to Paragraph 161 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 162. In response to Paragraph 162 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 163. In response to Paragraph 163 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 164. In response to Paragraph 164 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 165. In response to Paragraph 165 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

26

166.

In response to Paragraph 166 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 167. In response to Paragraph 167 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 168. In response to Paragraph 168 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 169. In response to Paragraph 169 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 170. In response to Paragraph 170 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 171. In response to Paragraph 171 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 172. In response to Paragraph 172 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

27

173.

In response to Paragraph 173 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 174. In response to Paragraph 174 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 175. In response to Paragraph 175 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 176. In response to Paragraph 176 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 177. In response to Paragraph 177 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 178. In response to Paragraph 178 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 179. In response to Paragraph 179 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

28

180.

In response to Paragraph 180 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 181. In response to Paragraph 181 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 182. In response to Paragraph 182 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 183. In response to Paragraph 183 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 184. In response to Paragraph 184 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 185. In response to Paragraph 185 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 186. In response to Paragraph 186 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

29

187.

In response to Paragraph 187 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 188. In response to Paragraph 188 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 189. In response to Paragraph 189 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 190. In response to Paragraph 190 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 191. In response to Paragraph 191 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 192. In response to Paragraph 192 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 193. In response to Paragraph 193 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

30

194.

In response to Paragraph 194 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 195. In response to Paragraph 195 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 196. In response to Paragraph 196 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 197. In response to Paragraph 197 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 198. In response to Paragraph 198 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 199. In response to Paragraph 199 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 200. In response to Paragraph 200 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

31

201.

In response to Paragraph 201 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 202. In response to Paragraph 202 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 203. In response to Paragraph 203 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 204. In response to Paragraph 204 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 205. In response to Paragraph 205 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 206. In response to Paragraph 206 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 207. In response to Paragraph 207 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

32

208.

In response to Paragraph 208 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 209. In response to Paragraph 209 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 210. In response to Paragraph 210 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 211. In response to Paragraph 211 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 212. In response to Paragraph 212 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 213. In response to Paragraph 213 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 214. In response to Paragraph 214 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

33

215.

In response to Paragraph 215 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 216. In response to Paragraph 216 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 217. In response to Paragraph 217 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 218. In response to Paragraph 218 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 219. In response to Paragraph 219 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 220. In response to Paragraph 220 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 221. In response to Paragraph 221 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

34

222.

In response to Paragraph 222 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 223. In response to Paragraph 223 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 224. In response to Paragraph 224 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 225. In response to Paragraph 225 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 226. In response to Paragraph 226 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 227. In response to Paragraph 227 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 228. In response to Paragraph 228 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

35

229.

In response to Paragraph 229 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 230. In response to Paragraph 230 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 231. In response to Paragraph 231 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 232. In response to Paragraph 232 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 233. In response to Paragraph 233 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 234. In response to Paragraph 234 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 235. In response to Paragraph 235 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

36

236.

In response to Paragraph 236 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 237. In response to Paragraph 237 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 238. In response to Paragraph 238 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 239. In response to Paragraph 239 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 240. In response to Paragraph 240 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 241. In response to Paragraph 241 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 242. In response to Paragraph 242 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

37

243.

In response to Paragraph 243 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 244. In response to Paragraph 244 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 245. In response to Paragraph 245 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 246. In response to Paragraph 246 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 247. In response to Paragraph 247 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 248. In response to Paragraph 248 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 249. In response to Paragraph 249 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

38

250.

In response to Paragraph 250 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 251. In response to Paragraph 251 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 252. In response to Paragraph 252 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 253. In response to Paragraph 253 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 254. In response to Paragraph 254 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 255. In response to Paragraph 255 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 256. In response to Paragraph 256 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

39

257.

In response to Paragraph 257 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 258. In response to Paragraph 258 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 259. In response to Paragraph 259 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 260. In response to Paragraph 260 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 261. In response to Paragraph 261 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 262. In response to Paragraph 262 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 263. In response to Paragraph 263 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

40

264.

In response to Paragraph 264 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 265. In response to Paragraph 265 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 266. In response to Paragraph 266 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 267. In response to Paragraph 267 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 268. In response to Paragraph 268 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 269. In response to Paragraph 269 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 270. In response to Paragraph 270 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

41

271.

In response to Paragraph 271 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 272. In response to Paragraph 272 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 273. In response to Paragraph 273 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 274. In response to Paragraph 274 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 275. In response to Paragraph 275 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 276. In response to Paragraph 276 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 277. In response to Paragraph 277 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

42

278.

In response to Paragraph 278 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 279. In response to Paragraph 279 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 280. In response to Paragraph 280 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 281. In response to Paragraph 281 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 282. In response to Paragraph 282 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 283. In response to Paragraph 283 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 284. In response to Paragraph 284 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same.

43

285.

In response to Paragraph 285 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 286. In response to Paragraph 286 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 287. In response to Paragraph 287 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 288. In response to Paragraph 288 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 289. In response to Paragraph 289 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 290. In response to Paragraph 290 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 291. Insofar as the claims in Paragraph 291of the Complaint relate to

contributory or induced infringement, VSDBM is not required to respond to the allegations in Paragraph 291 of the Complaint because it has filed concurrently herewith a Motion to Dismiss Parallel's claims of contributory and induced infringement. VSDBM denies the remaining allegations in Paragraph 291 of the Complaint.

44

292.

Insofar as the claims in Paragraph 292of the Complaint relate to indirect

infringement, VSDBM is not required to respond to the allegations in Paragraph 292 of the Complaint because it has filed concurrently herewith a Motion to Dismiss Parallel's claims of indirect infringement. VSDBM denies the remaining allegations in Paragraph 292 of the Complaint. 293. VSDBM is not required to respond to the allegations in Paragraph 293 of

the Complaint because it has filed concurrently herewith a Motion to Dismiss Parallel's claims of contributory and induced infringement. 294. Insofar as the claims in Paragraph 291 of the complaint relate to

contributory or induced infringement, VSDBM is not required to respond to the allegations in Paragraph 294 of the Complaint because it has filed concurrently herewith a Motion to Dismiss Parallel's claims of contributory and induced infringement. VSDBM denies the remaining allegations in Paragraph 294 of the Complaint. 295. In response to Paragraph 295 of the Complaint, VSDBM states that it

lacks knowledge or information sufficient to form a belief as to the truth or falsity of the allegations, and therefore denies same. 296. In response to Paragraph 296 of the Complaint, VSDBM states that it