Form 6G:12 Defendant's RFA - Copyright Infringement

REQUEST FOR ADMISSIONS

Admit or deny the following:

{INSERT APPLICABLE STANDARD REQUESTS - FORM 6G:3}

REQUEST 10: Plaintiff is not the owner of a work protected by copyright.

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REQUEST 11: Plaintiff's work is not an original work.

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REQUEST 12: Plaintiff created the work for defendant as a work for hire.

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REQUEST 13: Plaintiff's work that is the subject of this suit was not independently created.

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REQUEST 14: Plaintiff is not the author of the work claimed to be protected by copyright.

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REQUEST 15: Defendant has a valid license agreement with respect to plaintiff's work.

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REQUEST 16: Plaintiff is not entitled to claim ownership of the work claimed to be protected by copyright.

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REQUEST 17: The subject matter of plaintiff's work is not copyrightable.

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REQUEST 18: Plaintiff's work is in the public domain.

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REQUEST 19: Plaintiff distributed {his/her/its} work to the public without restriction.

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REQUEST 20: Defendant's work was not taken from plaintiff's work.

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REQUEST 21: Defendant's work was not copied from plaintiff's work.

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REQUEST 22: Defendant did not willfully copy plaintiff's work.

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REQUEST 23: Defendant had permission from the owner of the copyrighted work to copy it.

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REQUEST 24: Defendant did not have access to plaintiff's work.

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REQUEST 25: There are no similarities between defendant's work and plaintiff's work.

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REQUEST 26: Any similarities between defendant's work and plaintiff's work are coincidental.

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REQUEST 27: Defendant did not publish material that was copied from plaintiff's work.

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REQUEST 28: Defendant did not place material copied from plaintiff's work on the market.

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REQUEST 29: Defendant's use of plaintiff's work was not for profit.

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REQUEST 30: Defendant's use of plaintiff's work was a fair use.

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REQUEST 31: Plaintiff's work was abandoned.

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REQUEST 32: Plaintiff did not comply with the Copyright Act with respect to {his/her/its} work.

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