Page:Thaler v. Perlmutter, Answer to Complaint.pdf/1

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Case 1:22-cv-01564-BAH Document 11 Filed 09/26/22 Page 1 of 13

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

STEVEN THALER, an individual,

Plaintiff,
v.

SHIRA PERLMUTTER, in her official capacity as Register of Copyright and Director of the United States Copyright Office; and THE UNITED STATES COPYRIGHT OFFICE,

Defendants.
Civil Action No. 22-1564 (BAH)

Chief Judge Beryl A. Howell

ANSWER

Defendant, Shira Perlmutter, in her official capacity as Register of Copyright and Director of the United States Copyright Office, and Defendant, the United States Copyright Office, through undersigned counsel hereby answer the averments of Plaintiff’s Complaint. Each of the paragraphs numbered 1 to 66 responds to the corresponding paragraph in the Complaint. All averments in the Complaint are denied except for those expressly admitted to below. To the extent that the headings or any other non-numbered statements in the Complaint contain any allegations, Defendants deny each and every such allegation.

As to the initial, unnumbered paragraph, Defendants admit that Stephen Thaler is the Plaintiff and that Shira Perlmutter, in her official capacity as Register of Copyright and Director of the United States Copyright Office, and the United States Copyright Office (“Copyright Office”) are the Defendants. To the extent the paragraph is deemed to contain allegations that require a response, the same are denied.