I litigated cases for 12 years in Silicon Balley.
The shotgun defense is routine, nothing more, nothing less.
I don't know of any formal answers that do not dance that minuet: "The dog is not mine; there was no bite, there is no dog; I don't own a dog ,if you prove it is a dog, and if you prove it is my dog, it did not bite your client."
Since Ron is not posting right now, I will happily offer a word of caution (just so I can get my first "thumb's down": don't get excited about routine Answer filings.
Regardless of the Answer, there is a lot going on right now, and this board is second to none for its members' perceptive analysis and pithy insights.
This much--to quote SGE, whose posting I read regularly and respect--I know.
tps