In response to the allegations of paragraph 1, Defendant states that the paragraph sets forth the Intervenor-Plaintiffs theory of the case and as such does not require an answer. In response to the allegations of paragraph 2, Defendant admits that the Loudoun County Library is a public library in Loudoun County, Virginia, that provides its patrons access to a wide range of books and other information resources through funding allocated to the Defendant from the Loudoun County Board of Supervisors.
Defendant further admits that it presently provides patrons access to the Internet.
All other allegations of paragraph 2 are denied. In response to the allegations of paragraph 3, Defendant denies knowledge or information concerning the Intervenor Plaintiffs sufficient to form a belief as the accuracy of the allegations. In response to the allegations of paragraphs 5 and 6, Defendant states that after a diligent search of the available filtering software, the Director of Library Services advised Defendant that the X-Stop Library Edition software was the software best suited to implement the Policy. Defendant denies that the selection of sites to be filtered is under the control of an outside computer software vendor and states that the selection of sites to be filtered rests ultimately with Library personnel. The allegation in that clause is denied.