Defendant, Marques Rondale Gunter (hereinafter “Gunter”) created,owns and operates the websiteMyvidster.com(hereinafter“myVidster”). Defendant, Gunter d/b/a myVidster, has created a socialnetworking website through which site members, the Defendant JohnDoes, among others, can bookmark and store files of copyrightedmaterials and videos directly to myVidster and/or post links to thirdparty websites on which the files are available. On information andbelief, Defendant, Gunter, resides in the state of Indiana and Michiganat: 735 Lexington Avenue, Apt. 26, Indianapolis, Indiana 46203 and21022 Reimanville Avenue, Ferndale, Michigan 48220. Defendant,myVidster.com, is a domain name and website owned by Defendant,Gunter.
SalsaIndy admits the allegations of Paragraph 4 only with respect toGunter’s ownership of myVidster.com and residency. SalsaIndy denies each and everyremaining allegation of Paragraph 4.
On information and belief, Defendant, SalsaIndy, LLC is an entityformed, owned, controlled, managed and/or operated by Defendant,Gunter, in some connection with myVidster.
SalsaIndy denies the allegations of Paragraph 5 on the basis that the phrase“in some connection with” is vague and not understood.
On information and belief, at all relevant times, Defendants, John Does1-26 (hereinafter collectively “John Does” or individually “John Doe1,” “John Doe 2,” etc.), are individuals and/or business entities whosereal identities are currently unknown and whose whereabouts arecurrently unknown. On information and belief, Defendants, John Does1-26, actively contributed to this infringement by posting files, storingvideos, sharing files, and/or posting links on the site.
SalsaIndy is without sufficient knowledge to admit or deny the allegationsof paragraph 6 and therefore denies the same.
On information and belief, Voxel Dot Net, Inc. (“Voxel Dot Net”), wasthe domain server that hosted the website,myVidster.comat allrelevant times.
SalsaIndy denies the allegations of Paragraph 7.
Case: 1:10-cv-06517 Document #: 58 Filed: 06/22/11 Page 3 of 54 PageID #:1183