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Answer - Hilex Poly v. ChicoBag

Answer - Hilex Poly v. ChicoBag

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Published by Lara Pearson

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Published by: Lara Pearson on May 20, 2011
Copyright:Attribution Non-commercial

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05/20/2011

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UNITED STATES DISTRICT COURTFOR THE DISTRICT OF SOUTH CAROLINACOLUMBIA DIVISIONCivil Action No.: 3:11-cv-00116-JFA
HILEX POLY COMPANY, LLC
, )SUPERBAG OPERATING, LTD., )ADVANCE POLYBAG, INC., ))
Defendant’s Answerto
Plaintiffs, )
Plaintiff’s Complaintand
)
First Amended Complaint
-v- ))
CHICOECO, INC., doing business
)
as CHICOBAG
)
 
))
Defendant )
 ____________________________ )Defendant Chicoeco, Inc., d/b/a ChicoBag(hereafter “ChicoBag”), answersPlaintiffs’ Complaint as follows:1.ChicoBag denies each and every allegation, matter or thing contained in theComplaint, except as hereinafter admitted, qualified, alleged, or otherwisestated.
FOR A FIRST DEFENSE –GENERAL DENIALRESPONSE TO “NATURE OF THE ACTION”
2.The allegations of Paragraph1 of the Complaint constitute conclusions of lawto which no answer is required. To the extent an answer is deemed required,theseallegations are denied.3.ChicoBagadmits that Exhibit A of Plaintiffs’ Complaint shows examples of print advertisements for ChicoBag and that Exhibit B shows examples of Internet advertisements for ChicoBag.ChicoBag admits that Exhibit A and
3:11-cv-00116-JFA Date Filed 03/18/11 Entry Number 14 Page 1 of 9
 
2Exhibit B speakfor themselves.The remaining allegations of Paragraph2 of the Complaint are denied.4.The allegations of Paragraph3of the Complaint are denied.
RESPONSE TO PARTIES
5.ChicoBaglacks sufficient knowledge or information to admit or deny theallegations of Paragraphs 4, 5, and 6 of the Complaint, and accordingly, thesame are denied.6.ChicoBag admits that it is a business entity organized and existing under thelaws of the State of California, withprincipalplace of business at 345 HussDrive, Chico, California, 95928.7.The allegations of Paragraph8 of the Complaint are denied.
RESPONSE TO JURISDICTION AND VENUE
8.ChicoBag deniesthat this Court is the proper venue for the action. Theremaining allegations contained within Paragraph9 of the Complaint arealsodenied.9.ChicoBag admits that this Court has personal jurisdiction over the parties andthis matter. The remaining allegations contained within Paragraph10 of theComplaint are denied.10.The allegations of Paragraph11 constitute conclusions of law to which noanswer is required. To the extent an answer is deemed required, theallegations are denied.
3:11-cv-00116-JFA Date Filed 03/18/11 Entry Number 14 Page 2 of 9
 
3
RESPONSE TO “GENERAL ALLEGATIONS”
11.The allegations contained within Paragraph12 of the Complaint require noresponse, but to the extent theydo, the foregoing responses of ChicoBag areincorporated by reference.12.ChicoBag admits that it advertises, promotes, and sells reusable bags.ChicoBag’s advertisements and promotional materials speak for themselves.To the extent an answer is deemed required to the allegations of Paragraph13 of the Complaint, the allegations are denied.13.ChicoBag’s advertisements and promotional materials speak for themselves.To the extent an answer is deemed required to the allegations of Paragraph14 of the Complaint, the allegations are denied. ChicoBag denies that itsclaims cannot be substantiated.14.ChicoBag’s advertisements and promotional materials speak for themselves.To the extent an answer is deemed required to the allegations of Paragraph15 of the Complaint, the allegations are denied.15.ChicoBag’s advertisements and promotional materials speak for themselves.To the extent an answer is deemed required to the allegations of Paragraph16 of the Complaint, the allegations are denied. ChicoBag denies that itsclaims cannot be substantiated.16.ChicoBag’s advertisements and promotional materials speak for themselves.To the extent an answer is deemed required to the allegations of Paragraph
3:11-cv-00116-JFA Date Filed 03/18/11 Entry Number 14 Page 3 of 9

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