NeoMedia Technologies, Inc (NEOM)

[success622]

NeoMedia's response to ScanBuy filing:

WillaimFL shared a copy of the filing document, which he ordered through a service since it isn't available on Pacer. (Thanks again William!)

Briefly; this is a 10 page response, "NeoMedia's Reply to ScanBuy's Counterclaims". NeoMedia denies all of ScanBuy's allegations; not only denying that NEOM engaged in deliberate wrongful and injurious conduct designed to undermine their relations with third parties; but they also deny that they contacted third parties with whom ScanBuy has business relations or with whom ScanBuy was pursuing relations; and denying NEOM threatened any third parties with patent infringement lawsuits; and denies that as a result of any of NeoMedia's conduct that ScanBuy has suffered any harm. Very brief layperson's summary; but you should get the jist of it - NEOM denies all the allegations.

(Abbreviations and any typos etc. below are mine, they are not in the documents this way)
Section titled "affirmative defenses"
NEOM assets the following affirmative defenses against ScanBuy:
1. SB Counterclaims fail to state a claim upon which relief can be granted.
2. SB's Counterclaims are barred, in wholed or in part, by one or more of the docttines of fair use, waiver, acquiescense, laches, estoppel and unclean hands.
3. The patents-in-suit are valid.
4. SB has infringed the patents-in-suit.
5. NEOM has not tortiously interfered with SB's relations with prospective business parterns and/or customers.

Section titled "NEOM's request for relief:"
Wherefore, NEOM prays that the Court:

A. Deny the relief demanded on SB's counterclaims
B. Dismiss SB's counterclaims with prejudice,
C. Declare that SB has infringed the patents-in-suit,
E. Declare NEOM has not tortiously interfered with SB's prospective business relations,
F. Award NEOM its costs and attorney fees incurred in connectin w/ defending against the counterclaims,
G. Aware the relief that NEOM prayed for in the complaint, and
H. Other such relief as this Court or a jury may deem proper and just.