MALIBU MEDIA, LLC 

PLAINTIFF, 

V. 

DIANA FARLER, 

DEFENDANT. 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF INDIANA 

SOUTH BEND DIVISION 

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) Civil Action No. 3:13-CV-00071-JD-CAN 

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ANSWER TO AMENDED COMPLAINT 

Defendant, DIANA FARLER, ("Defendant") answers' Plaintiff MALIBU MEDIA, 

LLC's ("Plaintiff') Amended Complaint ("Complaint") as follows: 

ANSWER TO PARAGRAPH NO.1: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity ofthe 

allegations contained in paragraph number 1 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO.2: 

Defendant denies the allegations contained in paragraph number 2 of Plaintiff s 

Complaint. Further pleading, Defendant has been a long time member ofNetflix and Comcast. 

Defendant has paid for Netflix consistently since 2005 and has also been a long time customer of 

Comcast. See Netjlix email, attached as Exhibit 1. 

ANSWER TO PARAGRAPH NO.3: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 3 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

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ANSWER TO PARAGRAPH NO.4: 

Defendant admits the allegations contained in paragraph number 4 of the Complaint. 

ANSWER TO PARAGRAPH NO.5: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 5 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO.6: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 6 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO.7: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 7 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO.8: 

Defendant admits the allegations contained in paragraph number 8 of the Plaintiff s 

Complaint. 

ANSWER TO PARAGRAPH NO.9: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 9 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

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ANSWER TO PARAGRAPH NO. 10: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 10 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO. 11: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 11 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO. 12: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 12 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO. 13: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 13 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO. 14: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 14 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

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ANSWER TO PARAGRAPH NO. 15: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 15 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO. 16: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 16 of Plaintiffs' Complaint, and, therefore, denies the 

same. Further pleading, if Plaintiff's investigator, IPP Limited, established a direct TCPIIP 

connection with Defendant's IP address, then it proves that they hacked into Defendant's IP 

address without Defendant's knowledge and could have downloaded or uploaded anything 

without Defendant's knowledge. 

ANSWER TO PARAGRAPH NO. 17: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 17 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO. 18: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 18 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO. 19: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 19 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

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ANSWER TO PARAGRAPH NO. 20: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 20 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO. 21: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 21 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO. 22: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 22 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO. 23: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 23 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO. 24: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 24 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

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ANSWER TO PARAGRAPH NO. 25: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 25 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO. 26: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 26 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO. 27: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 27 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO. 28: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 28 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO. 29: 

Defendant lacks sufficient knowledge to form a belief as to the truth or falsity of the 

allegations contained in paragraph number 29 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

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ANSWER TO PARAGRAPH NO. 30: 

Defendant lacks sufficient knowledge to fonn a belief as to the truth or falsity of the 

allegations contained in paragraph number 30 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO. 31: 

Defendant lacks sufficient knowledge to fonn a belief as to the truth or falsity of the 

allegations contained in paragraph number 31 of Plaintiffs' Complaint, and, therefore, denies the 

same. 

ANSWER TO PARAGRAPH NO. 32: 

Defendant denies the allegations contained in paragraph number 32 of Plaintiffs' 

Complaint. 

WHEREFORE, Defendant DIANA FARLER ("Defendant") prays this Court for the 

entry of an Order against Plaintiff MALIBU MEDIA, LLC ("Plaintiff") as follows: 

A. denying the relief requested in, and dismissing all aspects of Plaintiffs' Complaint 

against her, with prejudice; 

B. awarding Defendant from Plaintiff a reimbursement of Defendant's attorneys' 

fees and costs, if any, associated with having to defend this action; and 

C. awarding Defendant from Plaintiff such other and further relief this Court deems 

just and equitable in the premises. 

Diana Farler 

531 Ohio Street 

Rochester, Indiana 46975 

7 

Respectfully submitted, 

DIANA FARLER 

By: Q ~&d/l6< ... /:1~Oc:kc j~, ProSe 

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