Case 3:16-cv-00811-AC

Document 21

Filed 10/07/16

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Thomas Freedman, OSB No. 080697

Email: thomas@prllaw.com
PEARL LAW LLC
522 SW 5th Ave. Suite 1100
Portland, OR 97204
Phone: 503.295.6296
Counsel for Defendant
UNITED STATES DISTRICT COURT
DISTRICT OF OREGON - PORTLAND DIVISION

CLEAR SKIES NEVADA, LLC.,

Plaintiff,

Case No. 3:16-cv-00811-AC

ANSWER
TO AMENDED COMPLAINT

-againstGRANT KAINU,
Defendant.

Defendant hereby answers plaintiffs amended complaint (the complaint) as follows:

1.

Defendant admits to downloading and viewing Good Kill via a public BitTorrent

network.
2.

Defendant generally denies the remaining allegations in the complaint.

WHEREFORE, defendant hereby prays for and demands judgment against plaintiff as
follows:
(i)

that plaintiff take nothing by way of the complaint;

(ii)

that plaintiffs complaint be dismissed in its entirety with prejudice;

(iii)

for costs and disbursements;

(iv)

for defendants attorneys fees to the extent permissible by applicable

law, including pursuant to 17 U.S.C. 505; and

Thomas Freedman, OSB No. 080697

522 SW 5th Ave. | Ste. 1100 | Portland, OR 97204
503.295.6296 | thomas@prllaw.com

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Answer to Amended Complaint

Case 3:16-cv-00811-AC

(v)

Document 21

Filed 10/07/16

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for such other and further relief as the court may deem just, equitable
and proper.

Dated: October 7, 2016

Respectfully submitted,
PEARL LAW LLC
By:

Thomas Freedman, OSB No. 080697

522 SW 5th Ave. | Ste. 1100 | Portland, OR 97204
503.295.6296 | thomas@prllaw.com

/s/ Thomas Freedman

Thomas Freedman, OSB No. 080697
Attorney for Defendant

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Answer to Amended Complaint