Case 1:22-cv-01564-BAH Document 11 Filed 09/26/22 Page 10 of 13
46. As to the first and second sentences of Paragraph 46, Defendants admit that “AI is not a legal person and does not have rights” and Defendants admit that AI cannot “‘own’ intellectual property.” The third and fourth sentences of Paragraph 46 include statements of law that require no response and conclusory statements made by Plaintiff that require no response. To the extent the paragraph is deemed to contain allegations that require a response, the same are denied.
47. As to the first sentence of Paragraph 47, Defendants lack knowledge and information sufficient to form a belief as to the truth of Plaintiff’s assertions and, the same are therefore, deemed denied. The second sentence of Paragraph 47 is a conclusory statement made by Plaintiff that require no response. To the extent the paragraph is deemed to contain allegations that require a response, the same are denied.
48. Paragraph 48, including the footnote, contains statements of law that require no response. Paragraph 48, including the footnote, also contains conclusory statements made by Plaintiff that require no response. To the extent the paragraph and footnote are deemed to contain allegations that require a response, the same are denied.
49. Paragraph 49 is a conclusory statement made by Plaintiff that requires no response. To the extent the paragraph is deemed to contain allegations that require a response, the same are denied.
50. Paragraph 50 includes statements of law that require no response. Paragraph 50 also includes conclusory statements made by Plaintiff that require no response. To the extent the paragraph is deemed to contain allegations that require a response, the same are denied.
