Anascape, Ltd v. Microsoft Corp. et al

Filing 49

ANSWER to Microsoft's Counterclaim by Anascape, Ltd.(Baxter, Samuel) Modified on 12/15/2006 (kjr, ).

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Anascape, Ltd v. Microsoft Corp. et al Doc. 49 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 1 of 45 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS LUFKIN DIVISION Anascape, Ltd., Plaintiff, v. Microsoft Corp., and Nintendo of America, Inc., Defendants. Civil Action No. 9:06-cv-158-RC JURY TRIAL REQUESTED ANASCAPE, LTD.'S FIRST AMENDED REPLY TO MICROSOFT CORPORATION'S COUNTERCLAIMS Plaintiff Anascape, Ltd. ("Anascape") files this Reply to Defendant Microsoft Corporation's ("Microsoft") Second Amended Counterclaims, filed December 6, 2006, and states as follows: RESPONSE TO COUNT I 1. Anascape admits that Microsoft purports to allege a counterclaim arising under 28 U.S.C. 1338, 2201, and 2202 and 35 U.S.C. Anascape denies that Microsoft is entitled to any declaratory relief. 2. 3. 4. 5. 6. Anascape admits the allegations of this paragraph. Anascape admits the allegations of this paragraph. Anascape admits the allegations of this paragraph. Anascape admits the allegations of this paragraph. Anascape admits that it commenced a civil action for infringement of the '084, '802, '886, '271, '525, '991, '791, '997, '205, '303, '415, and '700 patents and admits that there PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 1 Dockets.Justia.com Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 2 of 45 is an actual controversy between Anascape and Microsoft with respect to Microsoft's infringement of the '084, '802, '886, '271, '525, '991, '791,'997, '205, '303, '415, and '700 patents. Anascape denies the remaining allegations of this paragraph. 7. 8. Anascape denies the allegations of this paragraph. Anascape admits that Microsoft has sold at least two models of controllers for use with its original Xbox video game system. Anascape admits that photographs of two controllers are attached to Microsoft's First Amended Counterclaims as Exhibit A. Anascape admits that Microsoft refers to these two controllers as "Microsoft's Xbox Controllers." Because Microsoft has not yet provided any discovery regarding its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the remaining allegations of this paragraph and, therefore, denies the same. 9. Anascape admits that Microsoft has sold at least two models of controllers for use with its Xbox 360 video game system. Anascape admits that photographs of two controllers are attached to Microsoft's First Amended Counterclaims as Exhibit B. Anascape admits that Microsoft refers to these two controllers as "Microsoft's Xbox 360 Controllers." Because Microsoft has not yet provided any discovery regarding its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the remaining allegations of this paragraph and, therefore, denies the same. 10. 11. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 2 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 3 of 45 12. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 13. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 14. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 15. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 16. 17. 18. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 19. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 20. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 3 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 4 of 45 21. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 22. 23. 24. 25. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 26. 27. 28. 29. 30. 31. 32. 33. 34. 35. 36. 37. 38. 39. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 4 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 5 of 45 40. 41. 42. 43. 44. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 45. 46. 47. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 48. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 49. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 50. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 5 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 6 of 45 51. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 52. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 53. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 54. 55. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 56. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 57. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 58. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 6 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 7 of 45 59. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 60. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 61. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 62. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 63. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 64. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 65. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 7 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 8 of 45 66. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 67. 68. 69. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 70. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 71. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 72. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 73. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 74. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 8 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 9 of 45 75. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 76. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 77. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 78. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 79. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 80. 81. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 82. 83. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 9 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 10 of 45 84. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 85. 86. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 87. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 88. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 89. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 90. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 91. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 10 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 11 of 45 92. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 93. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 94. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 95. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 96. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 97. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 98. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 11 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 12 of 45 99. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 100. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 101. 102. 103. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 104. 105. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 106. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 107. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 108. 109. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 12 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 13 of 45 110. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 111. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 112. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 113. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 114. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 115. 116. 117. 118. 119. 120. 121. 122. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 13 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 14 of 45 123. 124. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 125. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 126. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 127. 128. 129. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 130. 131. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 132. 133. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 14 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 15 of 45 134. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 135. 136. 137. 138. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 139. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 140. 141. 142. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 143. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 144. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 15 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 16 of 45 145. 146. 147. 148. 149. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 150. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 151. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 152. 153. 154. 155. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 156. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 157. Anascape denies the allegations of this paragraph. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 16 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 17 of 45 158. 159. 160. 161. 162. 163. 164. 165. 166. 167. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 168. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 169. 170. 171. 172. 173. 174. 175. 176. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 17 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 18 of 45 177. 178. 179. 180. 181. 182. 183. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 184. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 185. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 186. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 187. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 18 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 19 of 45 188. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 189. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 190. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 191. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 192. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 193. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 194. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 195. 196. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 19 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 20 of 45 197. 198. 199. 200. 201. 202. 203. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 204. 205. 206. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 207. 208. 209. 210. 211. 212. 213. 214. 215. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 20 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 21 of 45 216. 217. 218. 219. 220. 221. 222. 223. 224. 225. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 226. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 227. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 228. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 21 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 22 of 45 229. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 230. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 231. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 232. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 233. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 234. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 235. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 22 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 23 of 45 236. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 237. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 238. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 239. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 240. 241. 242. 243. 244. 245. 246. 247. 248. 249. 250. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 23 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 24 of 45 251. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 252. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 253. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 254. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 255. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 256. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 257. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 24 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 25 of 45 258. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 259. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 260. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 261. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 262. 263. 264. 265. 266. 267. 268. 269. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 270. Anascape denies the allegations of this paragraph. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 25 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 26 of 45 271. 272. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 273. 274. 275. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 276. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 277. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 278. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 279. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 26 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 27 of 45 280. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 281. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 282. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 283. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 284. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 285. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 286. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 27 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 28 of 45 287. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 288. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 289. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 290. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 291. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 292. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 293. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 28 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 29 of 45 294. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 295. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 296. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 297. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 298. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 299. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 300. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 29 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 30 of 45 301. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 302. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 303. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 304. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 305. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 306. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 307. 308. 309. 310. 311. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 30 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 31 of 45 312. 313. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 314. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 315. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 316. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 317. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 318. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 319. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 31 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 32 of 45 320. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 321. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 322. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 323. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 324. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 325. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 326. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 327. 328. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 32 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 33 of 45 329. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 330. 331. 332. 333. 334. 335. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 336. 337. 338. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 339. 340. 341. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 33 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 34 of 45 342. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 343. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 344. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 345. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 346. 347. 348. Anascape denies the allegations of this paragraph. Anascape denies the allegations of this paragraph. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 349. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 350. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. PLAINTIFF'S REPLY TO MICROSOFT'S COUNTERCLAIMS Dallas 229790v1 PAGE 34 Case 9:06-cv-00158-RHC Document 49 Filed 12/14/2006 Page 35 of 45 351. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 352. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 353. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 354. Because Microsoft has not yet provided any discovery regarding the operation of its products, Anascape is without information or knowledge sufficient to form a belief as to the truth of the allegations of this paragraph and, therefore, denies the same. 355. Because Mic

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