3TAPS, INC.'S ANSWER AND COUNTERCLAIM Case No. CV-12 ...

12345678910111213141516171819202122232425262728services from those of craigslist. 3taps denies the remaining allegations in paragraph 67.68. 3taps admits that it used the word “craigslist” to distinguish its own product andservices from those of craigslist. 3taps denies the remaining allegations in paragraph 68. 3tapsalso denies the underlying factual implication that it has made any unlawful use of any ofcraigslist’s intellectual property, or that craigslist must “consent” prior to use of and access to usercreatedfactual content posted on craigslist for the purpose of publicizing it to the world.69. 3taps admits that it received a communication from craigslist to which 3tapsresponded, striking a conciliatory tone and agreeing to remove or adjust anything craigslistidentified as confusing any 3taps site with its own site. craigslist did not respond. 3taps denies thatit has conducted any unlawful activities.b. Complaint section titled, “PadMapper.”70. 3taps admits that PadMapper is a direct competitor to craigslist’s real estate listingservices and that PadMapper provides searchable rental listings in cities in the United States andUnited Kingdom, but denies the allegation that the vast majority of PadMapper’s content is copieddirectly from craigslist to the extent it suggests that 3taps violates craigslist’s Terms of Use,infringes any copyright protection asserted by craigslist, or violates any other law.71. 3taps admits that PadMapper offers many helpful features that are unavailable oncraigslist’s website. 3taps otherwise lacks knowledge or information sufficient to form a belief asto the truth of the allegations in paragraph 71 and therefore denies the same.72. 3taps lacks knowledge or information sufficient to form a belief as to the truth of theallegations in paragraph 72 and therefore denies the same.73. 3taps admits that PadMapper.com site traffic plummeted drastically when craigslistcontent was removed from the site. 3taps otherwise lacks knowledge or information sufficient toform a belief as to the truth of the allegations in paragraph 73 and therefore denies the same.74. 3taps lacks knowledge or information sufficient to form a belief as to the truth of theallegations in paragraph 74 and therefore denies the same.75. 3taps denies that it has misappropriated craigslist content. 3taps otherwise lacksknowledge or information sufficient to form a belief as to the truth of the allegations in paragraph3TAPS’ ANSWER AND COUNTERCLAIM17CASE NO.: 12-CV-3816-CRB