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Re: None

Tuesday, 03/15/2005 7:14:37 PM

Tuesday, March 15, 2005 7:14:37 PM

Post# of 432922
Pacer DE; for those waiting for the filings to be posted. The essence of IDCC's reply is:

Nokia's action should be dismissed because no actual controversy (under the law) exists;

alternatively, the court should exercise its "unique and substantial discretion" not to hear the case; and

the Lanham Act claim should be dismissed because it fails to state a claim upon which relief may be granted.

I'll let the attorneys take it from here, there're about 100 pages of stuff including 6 exhibits. JK
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