Free Answer to Complaint - District Court of Connecticut - Connecticut

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Case 3:00-cv-00327-JCH Document 125 Fnled 07/16/2004 Page 1 of 3 y
E: 2417-L00l lA
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I- IN THE UNITED STATES DISTRICT
FOR THE DISTRICT OF ; rg ;1i _
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HENRY A. KORSZUN; WOJTEK W. BOROWSKI i
and COMPUCLOZ CORPORATION : J
I : Civil Action No. 300CV327 (J CH)
Plaintiffs, : `
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: July 8, 2004
f Public Technologies Multimedia, Inc. : _?
I J .C. Penney Company, Inc; Mattel, Inc. : .
. and/or Broderbund Software, Inc.; and :
I Land's End, Inc. 2 I
p Defendants. : y
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REPLY TO FIRST AMENDED COUNTERCLAIMS OF
JC PENNY COMPANY, INC. J

|i Plaintiffs replies to the Counterclaims of Defendant J C Penny Company, Inc. as follows:
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} 36. The incorporation by reference of paragraphs l-20 requires no response. Paragraphs
21-35 are denied. I
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37. The allegations of paragraph 37 are admitted.
38. The allegations of paragraph 38 are admitted.
39. The allegations of paragraph 39 are admitted, noting that it is admitted only that
Defend ant. has made assertions of noninfringement and invalidity, without admission that these
assertic ns are correct.
40. The allegations of paragraph 40 are admitted. l
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· Case 3:00-cv-00327-JCH Document 125 Filed 07/16/2004 Page 2 of 3 °
41. The answers to paragraphs 36 to 40 are incorporated herein as if fully set forth.
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42. The allegations of paragraph 42 are denied.
? 43. The answers to paragraphs 36 to 42 are incorporated herein as if iirlly set forth. I
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I 44. The allegations of paragraph 44 are denied. I
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45. The answers to paragraphs 36 to 44 are incorporated herein as if fully set forth. Il
I 46. The allegations of paragraph 46 are denied. I
47. The answers to paragraphs 36 to 46 are incorporated herein as if fully set forth. T
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in 48. The allegations of paragraph 48 are denied. I
49. The answers to paragraphs 36 to 48 are incorporated herein as if fully set forth. I
I 50. The allegations of paragraph 50 are denied.
51. The answers to paragraphs 36 to 50 are incorporated herein as if fully set forth. I
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52. The allegations of paragraph 52 are denied. · I
Plaintiffs deny that Defendants are entitled to the requested relief

Respectfully submitted, I
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Date:S%% 7; EGGS! ‘ ' ° "‘
C tephen P. cNamara — ct 01220
Ric . `I . asile — ct 20491 Y
ST.ONGE STEWARD JOHNSTON & REENS LLC
986 Bedford Street
Stamford, Connecticut 06905
Telephone: (203) 324-6155
I Telecopier: (203) 327-1096
E Attorneys for Plaintiffs I
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. Case 3:00-cv-00327-JCH Document 125 Filed 07/16/2004 Page 3 of 3 -
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing REPLY TO FIRST l
AMENDED COUNTERCLAIMS OF JC PENNY COMPANY, INC., was sewed by first class
E mail, postage prepaid, in an envelope addressed to the following:
William H. Bright
fi McCarter & English, LLP
E CityPlace 1, 185 Asylum Street l
Hartford, Connecticut 06103 p
ia
And to l
James Hough
Morrison & Foerster LLP
Q 1290 Avenue of the Americas §
New York, New York 10104-0012 I
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