3RESPONSE NO. 5:
Dominion admits the allegations in Paragraph 5 of theComplaint.6.
Defendant Dominion Voting Systems, Inc. (“Dominion Voting”) is a corporationorganized and existing under the laws of Delaware.RESPONSE NO. 6:
Dominion admits the allegations in Paragraph 6 of theComplaint.7.
Defendant Dominion Voting Systems Corporation is a corporation organized andexisting under the laws of Canada.RESPONSE NO. 7:
Dominion denies the allegations in Paragraph 7 of theComplaint. By way of further response, Dominion clarifies that Dominion Canada is acorporation organized and existing under the laws of Ontario, Canada.8.
Defendants Dominion International, Dominion Voting, and Dominion VotingSystems Corporation will hereinafter be collectively referred to as “Dominion.”RESPONSE NO. 8:
Paragraph 8 of the Complaint contains Smartmatic’scharacterization of the parties to which no responsive pleading is required.9.
Defendant Iron Mountain Intellectual Property Management, Inc. (“IronMountain”) is a corporation organized and existing under the laws of Delaware.RESPONSE NO. 9:
Dominion lacks knowledge or information sufficient toform a belief as to the truth of the allegations in Paragraph 9 of the Complaint.
II. BACKGROUND FACTSA. Introduction
This lawsuit arises out of Dominion’s failure to honor its commitments toSmartmatic and its interference with Smartmatic’s business relationships in the Philippines,Mongolia, and Puerto Rico.RESPONSE NO. 10:
Dominion denies the allegations in Paragraph 10 of theComplaint, except admits that Smartmatic purports to bring a lawsuit against Dominion.