Case 1:12-cv-00886-MEH Document 89 Filed 10/23/12 USDC Colorado Page 2 of 123
Jurisdiction and Venue
Defendant denies that Plaintiff has any cause of action against him; however,
admits that this court has subject matter jurisdiction over matters involving federalquestions and copyrights.
Defendant denies the allegations of this paragraph. Even
question (184.108.40.206) was associated with the high-speed internet router located
or about January
2012, that fact would not give rise
jurisdiction over the Defendant's person.
not a person but adesignation assigned
a piece of technology, which can
accessed by multipleindividuals;
addition, in a process commonly known
stolen or misused as follows: other devices can
configured with the same
individual can utilize technology
make his or her
addressto appear to
Defendant denies the allegations of this paragraph, except to admit that
is aresident of the City of Louisville, County of Boulder, and State of Colorado.Defendant was not served with a Summons at the time of service of the Complaint,as required by the Federal Rules
Civil Procedure. For all of these reasons,Plaintiff has failed to plead facts from which a reasonable trier of fact could concludethat this Court has personal jurisdiction over Defendant, or that venue
this district. Defendant has
personal knowledge as to relevant informationregarding the other defendants
personal knowledge of these facts and can neither confirm nordeny and leaves Plaintiff to its proofs.