Case 1:22-cv-01564-BAH Document 11 Filed 09/26/22 Page 4 of 13
registration of a copyright application, as described in 17 U.S.C. § 701(a). Any remaining allegations are denied.
13. Defendants admit that the Copyright Office is a department of the Library of Congress and that the Copyright Office issues registrations regarding copyright claims and maintains records of copyright ownership.
FACTUAL BACKGROUND[1]
14. As to the first clause of the sentence of Paragraph 14, Defendants lack knowledge and information sufficient to form a belief as to the truth of the assertions and those assertions are deemed denied. The second clause of the sentence of Paragraph 14 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.
15. Defendants admit that Plaintiff’s copyright registration application in the work titled “A Recent Entrance to Paradise” (the “Work”) is the subject of instant action and that in the copyright registration application, the “author” of the Work is listed as “Creativity Machine.” Defendants further admit that the two-dimensional artwork reproduced in Paragraph 15 appears to be the Work, which is the subject of the copyright registration application at issue. Any remaining allegations are denied.
16. Defendants admit that on November 3, 2018, Plaintiff filed an application (“the Application”) to register the Work. Defendants further admit that the application was assigned the service request number 1-7100387071.
- ↑ The section headings of the Complaint from this point forward until “Causes of Action” have been omitted, as they are unnecessary and generally unhelpful. Omission of the headings is neither an admission nor denial of the content of the headings.
