Case 1:22-cv-01564-BAH Document 11 Filed 09/26/22 Page 3 of 13
7. Paragraph 7 is a conclusory statement that requires no response. To the extent the paragraph is deemed to contain allegations that require a response, Defendants lack knowledge and information sufficient to form a belief as to the truth of the allegations and the same are deemed denied.
JURISDICTION AND VENUE
8. Defendants admit that Plaintiff purports to bring an action under the Administrative Procedure Act (5 U.S.C. §§ 701-706). Defendants deny that all relief sought by Plaintiff is available under the Administrative Procedures Act. Further, Defendants admit that the Court has jurisdiction pursuant to 28 U.S.C. §§ 1331, 1338(a), and 1361. Defendants deny that 28 U.S.C. §§ 2201-2022 [sic] provides the Court “subject matter jurisdiction.”
9. Defendants admit that pursuant to 28 U.S.C. § 1391(e), venue is proper.
PARTIES
10. Defendants admit that Stephen Thaler, in his individual capacity, is identified as the Plaintiff. As to the remaining averments of Paragraph 10, Defendants lack knowledge and information sufficient to form a belief as to the truth of the averments and those averments are deemed denied.
11. Defendants admit that Plaintiff submitted a copyright registration application in the work titled “A Recent Entrance to Paradise” to the Copyright Office. Any remaining allegations are denied.
12. Defendants admit that Shira Perlmutter is Register of Copyrights and Director of the Copyright Office. Defendants further admit that the Register is responsible for overseeing the Copyright Office’s decision to register copyrights and has the authority to direct the
