Page:Thaler v. Perlmutter, Answer to Complaint.pdf/1



Defendant, Shira Perlmutter, in her official capacity as Register of CopyrightCopyrights [sic] and Director of the United States Copyright Office, and Defendant, the United States Copyright Office, through undersigned counsel hereby answer the averments of Plaintiff’s Complaint. Each of the paragraphs numbered 1 to 66 responds to the corresponding paragraph in the Complaint. All averments in the Complaint are denied except for those expressly admitted to below. To the extent that the headings or any other non-numbered statements in the Complaint contain any allegations, Defendants deny each and every such allegation.

As to the initial, unnumbered paragraph, Defendants admit that Stephen Thaler is the Plaintiff and that Shira Perlmutter, in her official capacity as Register of Copyright and Director of the United States Copyright Office, and the United States Copyright Office (“Copyright Office”) are the Defendants. To the extent the paragraph is deemed to contain allegations that require a response, the same are denied.