Page:Thaler v. Perlmutter, Answer to Complaint.pdf/13

 2. Defendants deny Paragraph 2 of the Prayer for Relief.

3. Defendants deny Paragraph 3 of the Prayer for Relief.

1. The Complaint fails to state a claim upon which relief can be granted. The Complaint contains solely legal conclusions and fails to allege any facts to support such conclusions.

2. The Copyright Office’s decision was not arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.

WHEREFORE, Defendant Shira Perlmutter, Register of Copyright and Director of the United States Copyright Office, and Defendant the United States Copyright Office pray that Plaintiff’s Complaint be dismissed and for such other and further relief as may be deemed appropriate.

Dated: September 26, 2022 Rh