Case 1:22-cv-01564-BAH Document 11 Filed 09/26/22 Page 12 of 13
58. Paragraph 58 includes statements of law that require no response. Paragraph 58 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.
59. Paragraph 59 includes statements of law that require no response. Paragraph 59 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.
60. Paragraph 60 includes statements of law that require no response. Paragraph 60 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.
CAUSES OF ACTION
FIRST CAUSE OF ACTION
(Administrative Procedure Act Violation for Denial of Plaintiff’s Application)
61. In response to Paragraph 61 of the Complaint, Defendants re-allege and incorporate the admissions and denials as stated in Paragraphs 1-60 above.
62. Defendants admit that the Copyright Office’s second refusal to register the Work is a final agency action. Defendants further admit that Plaintiff is seeking to reverse the Copyright Office’s refusal to register. Any remaining allegations of Paragraph 62 are denied.
63. Defendants deny Paragraph 63 of the Complaint.
64. Defendants deny Paragraph 64 of the Complaint.
65. Defendants deny Paragraph 65 of the Complaint.
66. Defendants deny Paragraph 66 of the Complaint.
PRAYER FOR RELIEF
1. Defendants deny Paragraph 1 of the Prayer for Relief.
