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
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Filed 12/14/2006
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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
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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
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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
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Document 49
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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
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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
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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
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Case 9:06-cv-00158-RHC
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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
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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.
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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
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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
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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.
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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
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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.
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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
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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.
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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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