In Atlantic v. Njuguna, in South Carolina, the RIAA's response to Ms. Njuguna's motion for judgment on the pleadings was not to attempt to defend their boilerplate, 'making available', complaint, but to cross-move for permission to file an amended complaint, in the new format used in other cases, which abandons the "making available" language and which falsely alleges that the plaintiffs "detected an individual".
Opposition to Motion for Judgment on Pleadings Dismissing Complaint*
Cross-motion for Leave to File Amended Complaint*
Proposed Amended Complaint*
Reply Memorandum in Support of Motion for Judgment on Pleadings Dismissing Complaint*
* Document published online at Internet Law & Regulation
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