Prayer For Relief
in response to
by
posted on
May 27, 2007 11:29AM
Wherefore, e.Digital prays for judgment against digEcor as follows:
1. Dismissing each and every claim in digEcor’s Complaint, with a declaration that digEcor take nothing against e.Digital thereunder;
2. Declaring that e.Digital is not in breach of any agreements with or any rights of digEcor, or is enjoined from marketing its eVU design in any market (as further explained above);
3. Awarding damages to e.Digital for digEcor’s breach of its agreements of confidentiality;
4. Awarding e.Digital damages for digEcor’s misappropriation of e.Digital’s trade secrets;
5. Enjoining digEcor’s manufacture or sale of their next generation digEplayer XT;
6. Awarding damages to e.Digital for digEcor’s breach of its duty to negotiate in good faith;
7. Enjoining digEcor’s tortious interference with e.Digital’s existing and prospective economic relations;
8. Awarding damages to e.Digital for digEcor’s tortious interference with e.Digital’s existing and prospective economic relations;
9. Enjoining digEcor’s defamatory statements;
10. Awarding damages to e.Digital for digEcor’s defamatory statements;
11. Declaring that digEcor shall indemnify e.Digital for any liability to e.Digital that might arise from digEcor’s use of unlicensed technology in its media players.
12. Awarding punitive or exemplary damages to e.Digital;
13. Awarding e.Digital its costs and attorneys’ fees incurred herein; and
14. For such other and further relief as the Court deems is just and proper.
DATED this 27th day of April, 2007.
RAY QUINNEY & NEBEKER, P.C.
/s/ Samuel C. Straight
James S. Jardine
Samuel C. Straight
Attorneys for Defendant<?xml:namespace prefix = o ns = "urn:schemas-microsoft-com:office:office" />