FIRST AFFIRMATIVE DEFENSE
The Counterclaim fails to state a claim upon which relief can be granted.
SECOND AFFIRMATIVE DEFENSE
The Counterclaim is barred, in whole or in part, by the doctrine of unclean hands.
THIRD AFFIRMATIVE DEFENSE
Any claim for unjust enrichment is not properly asserted against CBV, Inc., who sold the
Patents to ChanBond, LLC on or about April 9, 2015. As such, any claim for unjust enrichment
should be brought against ChanBond, LLC, not CBV, Inc.
FOURTH AFFIRMATIVE DEFENSE
The Counterclaim is barred, in whole or in part, by the doctrine of estoppel.
FIFTH AFFIRMATIVE DEFENSE
The Counterclaim is barred, in whole or in part, by Leane Defendants’ fraudulent
concealment.
SIXTH AFFIRMATIVE DEFENSE
The Counterclaim is barred, in whole or in part, by the doctrine of waiver.
SEVENTH AFFIRMATIVE DEFENSE
The Counterclaim is barred, in whole or in part, by the doctrine of accord and satisfaction.
EIGHTH AFFIRMATIVE DEFENSE
The Counterclaim is barred, in whole or in part, by the doctrine of issue preclusion.
RESERVATION OF RIGHTS
CBV reserves the right to amend this Answer and assert additional or further defenses or
claims based on information obtained during these proceedings, in discovery or otherwise.
_____________________________________
~ Paragraph X of the Counterclaim quotes the Hennenhoefer Transcript from the
Arbitration. The Hennenhoefer Transcript is a document, the terms and contents of which speak
for themselves. CBV notes that Leane Defendants failed to attach the Hennenhoefer Transcript to
their Counterclaim (despite that it is clearly integral thereto) and misleadingly quote selective
portions of the Hennenhoefer Transcript throughout their Counterclaim. CBV respectfully refers
to the entirety of the Hennenhoefer Transcript for the true and correct contents therein and denies
any allegations in Paragraph X inconsistent therewith
