Contract analysis

I. Response to Jurisdictional and Venue Allegations Paragraph 1. Plaintiff alleges that it is a Texas limited liability company organized under the laws of the State of Texas, with its principal office located at 802 Brazos Creek Lane, Suite 5, Austin, Texas 78701. Response: Redstone lacks sufficient knowledge or information to form a belief as to the truth of the allegations contained in Paragraph 1 of the Complaint

II. Response to Allegations Regarding Plaintiff Luminos Interactive LLC Paragraph 6. Plaintiff alleges that Luminos Interactive LLC is an independent game development studio that developed and published the video game titled Shardfall Chronicles. Response: Admitted that Luminos is an entity engaged in video game development. Redstone lacks sufficient knowledge or information to admit or deny the characterizations of

III. Response to Allegations Regarding Defendant Redstone Gaming Corp. Paragraph 11. Plaintiff alleges that Redstone Gaming Corp. is a publicly traded gaming and media/entertainment company. Response: Admitted. Redstone Gaming Corp. is a publicly traded gaming and interactive entertainment company listed on the Nasdaq Stock Market under the ticker symbol RDST. For the fiscal year ended December 31, 2023, Redstone rep

IV. Response to Allegations of Copyright Infringement Paragraph 15. Plaintiff alleges that it owns valid copyrights in Shardfall Chronicles and its constituent audiovisual elements. Response: Redstone admits that Luminos holds Copyright Registration No. VA 2-254-781 as reflected in the public records of the United States Copyright Office. Redstone denies, however, that such registration extends to or protects the gen

V. Response to Allegations of Damages Paragraph 23. Plaintiff alleges that it has been damaged in an amount of not less than $28.5 million, calculated as 9.13% of Ironclad Dominion's first-year revenue of $312 million, on the theory that the allegedly infringing assets accounted for approximately 9.13% of Ironclad Dominion's commercial appeal. Response: Denied. Luminos's damages calculation is speculative, unsupporte

VI. General Denial Except as specifically and expressly admitted herein, Redstone denies each and every allegation contained in the Complaint, including but not limited to any allegations, implications, characterizations, or conclusions of law set forth in the Complaint's introductory paragraphs, headings, prayer for relief, or any other section not separately addressed above. AFFIRMATIVE DEFENSES Without assuming th

1. That the Complaint be dismissed in its entirety, with prejudice, and that Plaintiff take nothing by its claims;

2. That judgment be entered in favor of Redstone and against Luminos on each and every claim and cause of action asserted in the Complaint;

3. That Redstone be awarded its reasonable attorney's fees and costs incurred in the defense of this action, pursuant to 17 U.S.C. § 505 and any other applicable provision of law;

4. That Redstone be awarded such other and further relief as this Court deems just, proper, and equitable under the circumstances. JURY DEMAND Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Defendant Redstone Gaming Corp. hereby demands a trial by jury on all issues and claims in this action so triable as of right. Dated: April 22, 2024 Respectfully submitted, CALDERWOOD & HARKNESS LLP By: ________ C