Case 3:14-cv-00757-REP-DJN Document 52 Filed 01/26/15 Page 1 of 383 PageID# 2168
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`Richmond Division
`
`Plaintiff,
`
`
`
`SAMSUNG ELECTRONICS CO. LTD., et.
`al.,
`
`
`
`v.
`
`NVIDIA CORPORATION, et. al.
`
`
`
`
`Defendant.
`
`
`
`
`
`
`CIVIL ACTION NO. 3:14cv757-REP
`
`JURY TRIAL DEMANDED
`
`
`)
`)
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`)
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`DEFENDANT VELOCITY HOLDINGS, LLC’S ANSWER TO AMENDED
`COMPLAINT
`
`Defendant Velocity Holdings, LLC (“Defendant”), by and through its undersigned
`
`attorneys, hereby file this Answer to Plaintiffs Samsung Electronics Company, Ltd. (“SEC”) and
`
`Samsung Electronics America, Inc.’s (“SEA”) (collectively “Plaintiffs” or “Samsung”) First
`
`Amended Complaint. Defendant states as follows:
`
`THE PARTIES
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`1.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`2.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`3.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`4.
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`5.
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`Defendant denies the allegations in this paragraph.
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`Defendant admits the allegations in this paragraph.
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`

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`SAMSUNG
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`6.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`7.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`8.
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`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`9.
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`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`10.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`11.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`12.
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`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`13.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`14.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`15.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`16.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`2
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`

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`NVIDIA
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`17.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`18.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`19.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`20.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`21.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`VELOCITY
`
`22.
`
`Defendant admits
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`that Velocity Holdings, LLC produces custom high-
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`performance computers designed for gaming, digital graphic design, home theater use, and
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`common home and office use and that Velocity Holdings, LLC provides scientific workstations.
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`Defendant denies the remaining allegations.
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`23.
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`Defendant avers that the referenced documents speak for themselves, and
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`otherwise denies the allegations of this paragraph, including all characterizations of the
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`documents beyond the text of the document and distortions via selective excerpts.
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`24.
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`Defendant avers that the referenced documents speak for themselves, and
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`otherwise denies the allegations of this paragraph, including all characterizations of the
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`documents beyond the text of the document and distortions via selective excerpts.
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`3
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`

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`25.
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`Defendant avers that the referenced documents speak for themselves, and
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`otherwise denies the allegations of this paragraph, including all characterizations of the
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`documents beyond the text of the document and distortions via selective excerpts.
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`26.
`
`Defendant avers that the referenced documents speak for themselves, and
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`otherwise denies the allegations of this paragraph, including all characterizations of the
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`documents beyond the text of the document and distortions via selective excerpts.
`
`27.
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`Defendant avers that the referenced documents speak for themselves, and
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`otherwise denies the allegations of this paragraph, including all characterizations of the
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`documents beyond the text of the document and distortions via selective excerpts.
`
`28.
`
`Defendant avers that the referenced documents speak for themselves, and
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`otherwise denies the allegations of this paragraph, including all characterizations of the
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`documents beyond the text of the document and distortions via selective excerpts.
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`29.
`
`Defendant admits that Velocity Holdings, LLC sells computers, some of which
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`may incorporate NVIDIA GPUs, and denies all remaining allegations in this paragraph.
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`30.
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`The allegations in this paragraph contain subjective assessments from Plaintiffs
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`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
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`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
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`31.
`
`Defendant admits that Velocity Holdings, LLC sells products and services in the
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`Commonwealth of Virginia. Defendant denies that they infringe any valid and enforceable claim
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`of the Asserted Patents. Defendant avers that the referenced document speaks for itself, and
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`otherwise denies the remaining allegations of this paragraph, including all characterizations of
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`the documents beyond the text of the document and distortions via selective excerpt
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`4
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`

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`Case 3:14-cv-00757-REP-DJN Document 52 Filed 01/26/15 Page 5 of 383 PageID# 2172
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`JURISDICTION AND VENUE
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`32.
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`Defendant admits that this action purports to arise under the patent laws of the
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`United States, Title 35 of the United States Code, but denies that this action has any merit or that
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`Plaintiffs are entitled to the relief sought. Defendant also admits that this Court has subject
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`matter jurisdiction, but denies the remaining allegations of this paragraph.
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`33.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`34.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`35.
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`Defendant admits that Velocity Holdings, LLC conducts business activities within
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`the Commonwealth of Virginia, but denies that they infringe any valid and enforceable claim of
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`the Asserted Patents. To the extent this paragraph also contains conclusions of law and not
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`averments of facts to which an answer is required, but insofar as an answer may be deemed
`
`required, Defendant denies them.
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`36.
`
`Defendant admits that Velocity Holdings, LLC sells products nationwide,
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`including in Virginia, but denies that they infringe any valid and enforceable claim of the
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`Asserted Patents, and denies all other allegations in this paragraph.
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`37.
`
`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`38.
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`Defendant avers that the referenced documents speak for themselves, and
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`otherwise denies the allegations of this paragraph, including all characterizations of the
`
`documents beyond the text of the document and distortions via selective excerpts.
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`39.
`
`Defendant admits that Velocity Holdings, LLC was registered as a corporation
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`with the Commonwealth of Virginia and appointed as its registered agent Gary S Cook, 4551
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`5
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`

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`Cox Rd Suite 210, Glen Allen, VA 23060, and denies any remaining allegations in this
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`paragraph.
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`40.
`
`Defendant denies the allegations in this paragraph.
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`ACCUSED PRODUCTS
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`41.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`42.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`43.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`44.
`
`45.
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`Defendant denies the allegations in this paragraph.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`46.
`
`47.
`
`Defendant denies the allegations in this paragraph.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`48.
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`The allegations in this paragraph contain subjective assessments from Plaintiffs
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`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
`
`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
`
`49.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`50.
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`The allegations in this paragraph contain subjective assessments from Plaintiffs
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`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
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`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
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`6
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`

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`51.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`52.
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`The allegations in this paragraph contain subjective assessments from Plaintiffs
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`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
`
`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
`
`53.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`54.
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`The allegations in this paragraph contain subjective assessments from Plaintiffs
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`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
`
`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
`
`55.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`56.
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`The allegations in this paragraph contain subjective assessments from Plaintiffs
`
`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
`
`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
`
`57.
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`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`58.
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`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`59.
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`The allegations in this paragraph contain subjective assessments from Plaintiffs
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`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
`
`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
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`7
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`

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`60.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`61.
`
`The allegations in this paragraph contain subjective assessments from Plaintiffs
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`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
`
`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
`
`62.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`63.
`
`The allegations in this paragraph contain subjective assessments from Plaintiffs
`
`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
`
`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
`
`64.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`65.
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`The allegations in this paragraph contain subjective assessments from Plaintiffs
`
`and the accuracy of the allegations depends on context. Defendant therefore denies them as it
`
`lacks knowledge or information sufficient to form a belief about the truth of the allegations.
`
`66.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`67.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`68.
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`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`69.
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`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`8
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`70.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`71.
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`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`72.
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`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`73.
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`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`74.
`
`Defendant admits that the NoteMagix M15, NoteMagix M17, NoteMagix M15
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`Ultra, and NoteMagix M17 Ultra may include DisplayPort, and denies any remaining
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`allegations.
`
`75.
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`Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`REFERENCES
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`76.
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`This paragraph contains no factual allegations that require a response, but to the
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`extent a response is required, Defendant admits that Plaintiffs produced a document so
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`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
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`any remaining allegations set forth in this paragraph, and on that basis denies them.
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`77.
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`This paragraph contains no factual allegations that require a response, but to the
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`extent a response is required, Defendant admits that Plaintiffs produced a document so
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`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`78.
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`This paragraph contains no factual allegations that require a response, but to the
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`extent a response is required, Defendant admits that Plaintiffs produced a document so
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`9
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`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
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`any remaining allegations set forth in this paragraph, and on that basis denies them.
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`79.
`
`Defendant avers that the referenced documents speak for themselves, and
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`otherwise denies the allegations of this paragraph, including all characterizations of the
`
`documents beyond the text of the document and distortions via selective excerpts.
`
`80.
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`This paragraph contains no factual allegations that require a response, but to the
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`extent a response is required, Defendant admits that Plaintiffs produced a document so
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`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`81.
`
`Defendant avers that the referenced documents speak for themselves, and
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`otherwise denies the allegations of this paragraph, including all characterizations of the
`
`documents beyond the text of the document and distortions via selective excerpts.
`
`82.
`
`This paragraph contains no factual allegations that require a response, but to the
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`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`83.
`
`Defendant avers that the referenced documents speak for themselves, and
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`otherwise denies the allegations of this paragraph, including all characterizations of the
`
`documents beyond the text of the document and distortions via selective excerpts.
`
`84.
`
`This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
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`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
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`any remaining allegations set forth in this paragraph, and on that basis denies them.
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`10
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`85.
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`Defendant avers that the referenced documents speak for themselves, and
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`otherwise denies the allegations of this paragraph, including all characterizations of the
`
`documents beyond the text of the document and distortions via selective excerpts.
`
`86.
`
`This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`87.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`88.
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`This paragraph contains no factual allegations that require a response, but to the
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`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`89.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`90.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`91.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`92.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`93.
`
`This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`11
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`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
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`any remaining allegations set forth in this paragraph, and on that basis denies them.
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`94.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`95.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`96.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`97.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`98.
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`This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`99.
`
`Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`100. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`101. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`102. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`12
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`103. This paragraph contains no factual allegations that require a response, but to the
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`extent a response is required, Defendant admits that Plaintiffs produced a document so
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`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`104. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`105. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`106. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`107. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`108. This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`109. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`110. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`111. This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`13
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`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
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`any remaining allegations set forth in this paragraph, and on that basis denies them.
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`112. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`113. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`114. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`115. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`116. This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
`
`117. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
`
`118. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`119. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`120. Defendant is without knowledge or information sufficient to form a belief as to
`
`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`14
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`Case 3:14-cv-00757-REP-DJN Document 52 Filed 01/26/15 Page 15 of 383 PageID# 2182
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`121. This paragraph contains no factual allegations that require a response, but to the
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`extent a response is required, Defendant admits that Plaintiffs produced a document so
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`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
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`any remaining allegations set forth in this paragraph, and on that basis denies them.
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`122. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`123. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`124. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`125. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`126. This paragraph contains no factual allegations that require a response, but to the
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`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
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`any remaining allegations set forth in this paragraph, and on that basis denies them.
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`127. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`128. This paragraph contains no factual allegations that require a response, but to the
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`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
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`Case 3:14-cv-00757-REP-DJN Document 52 Filed 01/26/15 Page 16 of 383 PageID# 2183
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`129. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`130. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`131. This paragraph contains no factual allegations that require a response, but to the
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`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
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`132. This paragraph contains no factual allegations that require a response, but to the
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`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
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`133. This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
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`134. This paragraph contains no factual allegations that require a response, but to the
`
`extent a response is required, Defendant admits that Plaintiffs produced a document so
`
`numbered, but is without knowledge or information sufficient to form a belief as to the truth of
`
`any remaining allegations set forth in this paragraph, and on that basis denies them.
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`135. Defendant is without knowledge or information sufficient to form a belief as to
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`the truth of the allegations set forth in this paragraph, and on that basis denies them.
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`16
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`Case 3:14-cv-00757-REP-DJN Document 52