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ANTON HANDAL (Bar No. 113812)
PAMELA C. CHALK (Bar No. 216411)
GABRIEL HEDRICK (Bar No. 220649)
H
ANDAL & ASSOCIATES
1200 Third Avenue, Suite 1321
San Diego, California 92101
Attorneys for Plaintiff and Counter-Defendant
e.Digital Corporation
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
e.Digital Corporation,
Plaintiff,
v.
Patriot Memory, LLC,
Defendant.
And related counterclaims.
Case No. 3:13-cv-2916-H-BGS
PLAINTIFF AND COUNTERDEFENDANT
E.DIGITAL
CORPORATION’S ANSWER TO
COUNTERCLAIMS OF
DEFENDANT AND
COUNTERCLAIMANT
PATRIOT MEMORY, LLC
Assigned to the Honorable
Judge Marilyn L. Huff
Courtroom 15A (Annex)
Plaintiff and Counter-Defendant e.Digital Corporation (hereinafter
“Plaintiff” or “e.Digital”) hereby replies to and answers the Counterclaims
(“Counterclaim”) of Defendant and Counterclaimant Patriot Memory, LLC
(hereafter referred to as “Defendant” or “Patriot”) as follows:
PARTIES
1. Admitted.
2. Admitted.
JURISDICTION AND VENUE
3. Admitted.
4. e.Digital admits that there is a controversy between the parties that
should be resolved in this judicial forum, but denies that Defendant is entitled to
any relief. Except as expressly admitted, e.Digital denies each and every
remaining allegation made in Paragraph 4 of the Counterclaim.
COUNT I:
DECLARATORY RELIEF REGARDING NON-INFRINGEMENT
5. e.Digital admits that there is a controversy between the parties that
should be resolved in this judicial forum, but denies that Defendant is entitled to
any relief. Except as expressly admitted, e.Digital denies each and every
remaining allegation made in Paragraph 5 of the Counterclaim.
6. e.Digital denies each and every allegation made in Paragraph 6 of the
Counterclaim and denies that Defendant is entitled to any relief.
COUNT II:
DECLARATORY RELIEF REGARDING INVALIDITY
7. e.Digital admits that there is a controversy between the parties that
should be resolved in this judicial forum, but denies that Defendant is entitled to
any relief. Except as expressly admitted, e.Digital denies each and every
remaining allegation made in Paragraph 7 of the Counterclaim.
8. e.Digital denies each and every allegation made in Paragraph 8 of the
Counterclaim denies that Defendant is entitled to any relief.
REPLY TO DEFENDANT’S PRAYER FOR JUDGMENT
9. Because Defendant’s prayer for relief and/or prayer for judgment does
not state any allegation, no response by e.Digital is required. However, e.Digital
denies that the Defendant is entitled to any relief whatsoever, including any relief
requested in Subparagraphs 1 through 6 of the Prayer for Relief portion of the
Counterclaim (Pages 7-8 of the Defendant’s Answer/Counterclaim, Docket #13).
Dated: April 10, 2014
HANDAL & ASSOCIATES
By: /s/Pamela C. Chalk
Anton N. Handal
Pamela C. Chalk
Gabriel G. Hedrick
Attorneys for Plaintiff
e.Digital Corporation
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