IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 07-cv-00630-DME-MEH
NETQUOTE, INC., a Colorado corporation,
Plaintiff,
v.
BRANDON BYRD, an internet user making use of the IP Addresses 64.136.27.226 and
64.136.26.227, and
MOSTCHOICE.COM, INC., a Georgia corporation,
Defendants.
PLAINTIFF’S REPLY TO AMENDED COUNTERCLAIM
Plaintiff NetQuote, Inc., (“NetQuote”), by and through counsel, Faegre & Benson LLP,
submits this Reply to Defendant Mostchoice.com, Inc.’s (“Mostchoice”) Amended
Counterclaim in the above-captioned matter, and states as follows:
Jurisdictional Allegations
1.
NetQuote admits the allegations contained in Paragraph 1 of the Amended
Counterclaim.
2.
NetQuote admits that Mostchoice is Georgia corporation. NetQuote is without
knowledge or information sufficient to form a belief as to the truth or falsity of the allegations
contained in Paragraph 2 of the Amended Counterclaim, and therefore denies the same.
Case 1:07-cv-00630-DME-MEH Document 76 Filed 08/23/2007 Page 1 of 6
Netquote Inc. v. Byrd
Doc. 76
Dockets.Justia.com
2
3.
NetQuote is without knowledge or information sufficient to form a belief as to the
truth or falsity of the allegations contained in Paragraph 3 of the Amended Counterclaim, and
therefore denies the same.
4.
NetQuote admits the allegations contained in Paragraph 4 of the Amended
Counterclaim.
5.
Paragraph 5 of the Amended Counterclaim calls for a legal conclusion as to which
no response is required.
6.
Paragraph 6 of the Amended Counterclaim calls for a legal conclusion as to whch
no response is required.
7.
NetQuote denies the allegations contained in Paragraph 7 of the Amended
Counterclaim.
8.
Paragraph 8 of the Amended Counterclaim calls for a legal conclusion as to which
no response is required. To the extent that a response is required, denied.
Click Fraud
9. – 22. No response is required to Paragraphs 9 through 22 of the Amended
Counterclaim at this time because NetQuote is moving to dismiss the fraud claim for failure to
state