Case 1:22-cv-01564-BAH Document 11 Filed 09/26/22 Page 5 of 13
17. The Application Plaintiff submitted to the Copyright Office speaks for itself. To the extent the allegations of Paragraph 17 paraphrase or characterize the Application, Defendants deny the allegations to the extent they are inconsistent with the Application. Any remaining allegations are denied.
18. The Application Plaintiff submitted to the Copyright Office speaks for itself. To the extent the allegations of Paragraph 18 paraphrase or characterize the Application, Defendants deny the allegations to the extent they are inconsistent with the Application. Any remaining allegations are denied.
19. Defendants admit that the Copyright Office sent a refusal letter to Plaintiff dated August 12, 2019. The refusal letter speaks for itself. To the extent the allegations of Paragraph 19 paraphrases or characterizes the letter, Defendants deny the allegations to the extent they are inconsistent with the letter. Any remaining allegations are denied.
20. Defendants admit that Plaintiff submitted two requests for reconsideration, one on September 23, 2019[1] and one on May 27, 2020. The requests Plaintiff submitted to the Copyright Office speak for themselves. To the extent the allegations of Paragraph 20 paraphrase or characterize the requests, Defendants deny the allegations to the extent they are inconsistent with the requests. Any remaining allegations are denied.
21. Defendants admit that the Copyright Office sent a first refusal letter to Plaintiff dated March 30, 2020. The letter speaks for itself. To the extent the allegations of Paragraph 21 paraphrase or characterize the letter, Defendants deny the allegations to the extent they are inconsistent with the letter. Any remaining allegations are denied.
- ↑ Defendants note that the top of Plaintiff’s First Request is dated September 8, 2019, but the attorney’s signature block has a date of September 23, 2019.
