Case 5:20-cv-05290-EJD Document 102 Filed 12/30/24 Page 1 of 13
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`DAVID H. KRAMER, SBN 168452
`Email: dkramer@wsgr.com
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`Telephone: (650) 493-9300
`
`Counsel for Defendant
`PINTEREST, INC.
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`
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`CASE NO.: 5:20-cv-05290-EJD
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`DEFENDANT PINTEREST, INC.’S
`ANSWER TO PLAINTIFF’S THIRD
`AMENDED CLASS ACTION
`COMPLAINT
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`
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`The Honorable Edward J. Davila
`
`
`MAUREEN HARRINGTON, as the
`representative of the Estate of Blaine Harrington
`III, and HAROLD DAVIS, on behalf of
`themselves and others similarly situated,
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`Plaintiffs,
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`v.
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`PINTEREST, INC.,
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`Defendant.
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`DEFENDANT PINTEREST’S ANSWER TO TAC
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`CASE NO.: 5:20-CV-05290-EJD
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`Case 5:20-cv-05290-EJD Document 102 Filed 12/30/24 Page 2 of 13
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`PRELIMINARY STATEMENT
`Defendant Pinterest, Inc. (“Defendant”) hereby answers the Third Amended Complaint
`(“TAC”).
`To the extent the Paragraphs of the TAC (“Paragraphs”) are grouped under headings and
`subheadings, Defendant responds generally that such headings and subheadings (some of which
`are repeated below for reference only and which do not constitute admissions) state legal
`conclusions to which no response is required. To the extent a response is required, Defendant
`denies each and every heading and subheading in the TAC and incorporates by reference this
`response in each Paragraph below as if fully set forth herein.
`Defendant further objects that, rather than a short and plain statement of Plaintiff’s1
`allegations and claims required by Federal Rule of Civil Procedure 8, the TAC is a narrative with
`paragraph after paragraph of advocacy, including images embedded into the TAC accompanied by
`mark-ups and captions. The complex rhetoric and built-in assumptions in the TAC make
`straightforward responses often impossible.
`Except as expressly admitted herein, Defendant denies any and all allegations as set forth
`in the TAC. Defendant expressly reserves the right to amend and/or supplement its Answer as may
`be necessary. Defendant further answers the numbered Paragraphs in the TAC as follows:
`INTRODUCTION
`1.
`Defendant admits that it was incorporated in 2008 and that it has hundreds of millions
`of monthly active users. Defendant denies the remaining allegations in Paragraph 1.
`2.
`Defendant denies the allegations in Paragraph 2.
`3.
`Defendant admits that it enables Pinterest users to “pin” images from the internet and
`elsewhere and that users have saved billions of images on the service. Defendant denies the
`remaining allegations in Paragraph 3.
`4.
`Defendant denies the allegations in Paragraph 4.
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`1 Blaine Harrington III brought this case in his personal capacity. Maureen Harrington III, as
`representative of Mr. Harrington’s estate, was substituted as plaintiff following Mr. Harrington’s
`death. ECF No. 77. For purposes of this Answer, the term “Plaintiff” refers to Mr. Harrington
`and/or his estate, as applicable.
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`DEFENDANT PINTEREST’S ANSWER TO TAC
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`-1-
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`CASE NO.: 5:20-CV-05290-EJD
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`Case 5:20-cv-05290-EJD Document 102 Filed 12/30/24 Page 3 of 13
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`5.
`Defendant denies the allegations in Paragraph 5.
`6.
`Defendant admits that the TAC purports to assert a claim for copyright
`infringement. Defendant denies that the TAC alleges adequate factual or legal predicates for that
`claim and otherwise denies the allegations in Paragraph 6.
`PARTIES
`A.
`Plaintiff Maureen Harrington
`7.
`Defendant lacks knowledge or information sufficient to form a belief about the truth
`of the allegations in Paragraph 7 and, on that basis, denies them.
`8.
`Defendant lacks knowledge or information sufficient to form a belief about the truth
`of the allegations in Paragraph 8 and, on that basis, denies them.
`9.
`Defendant lacks knowledge or information sufficient to form a belief about the truth
`of the allegations in Paragraph 9 and, on that basis, denies them.
`10.
`Defendant lacks knowledge or information sufficient to form a belief about the truth
`of the allegations in Paragraph 10 and, on that basis, denies them.
`B.
`Plaintiff Harold Davis
`11.
`There are no allegations to answer in this paragraph because the allegations pertain
`solely to Harold Davis, who has been dismissed from the action with prejudice. ECF No. 100 at
`7. To the extent a response is required, Defendant lacks knowledge or information sufficient to
`form a belief about the truth of the allegations in Paragraph 11 and, on that basis, denies them.
`12.
`There are no allegations to answer in this paragraph because the allegations pertain
`solely to Harold Davis, who has been dismissed from the action with prejudice. ECF No. 100 at
`7. To the extent a response is required, Defendant lacks knowledge or information sufficient to
`form a belief about the truth of the allegations in Paragraph 12 and, on that basis, denies them.
`13.
`There are no allegations to answer in this paragraph because the allegations pertain
`solely to Harold Davis, who has been dismissed from the action with prejudice. ECF No. 100 at
`7. To the extent a response is required, Defendant lacks knowledge or information sufficient to
`form a belief about the truth of the allegations in Paragraph 13 and, on that basis, denies them.
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`DEFENDANT PINTEREST’S ANSWER TO TAC
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`-2-
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`CASE NO.: 5:20-CV-05290-EJD
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`Case 5:20-cv-05290-EJD Document 102 Filed 12/30/24 Page 4 of 13
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`14.
`There are no allegations to answer in this paragraph because the allegations pertain
`solely to Harold Davis, who has been dismissed from the action with prejudice. ECF No. 100 at
`7. To the extent a response is required, Defendant lacks knowledge or information sufficient to
`form a belief about the truth of the allegations in Paragraph 14 and, on that basis, denies them.
`15.
`There are no allegations to answer in this paragraph because the allegations pertain
`solely to Harold Davis, who has been dismissed from the action with prejudice. ECF No. 100 at
`7. To the extent a response is required, Defendant lacks knowledge or information sufficient to
`form a belief about the truth of the allegations in Paragraph 15 and, on that basis, denies them.
`16.
`There are no allegations to answer in this paragraph because the allegations pertain
`solely to Harold Davis, who has been dismissed from the action with prejudice. ECF No. 100 at
`7. To the extent a response is required, Defendant lacks knowledge or information sufficient to
`form a belief about the truth of the allegations in Paragraph 16 and, on that basis, denies them.
`C.
`Defendant Pinterest
`17.
`Defendant admits the allegations in Paragraph 17.
`18.
`Defendant admits that it owns and operates the online domains listed in Paragraph
`18. Defendant denies that it is “solely responsible for the content of its websites” and otherwise
`denies the remaining allegations in Paragraph 18.
`JURISDICTION AND VENUE
`19.
`Defendant admits the allegations in Paragraph 19.
`20.
`Defendant admits that this Court has personal jurisdiction over it for this matter
`because it is headquartered in this judicial district. Paragraph 20 otherwise sets forth legal
`conclusions to which no response is required. To the extent a response is required, Defendant
`denies the remaining allegations in Paragraph 20.
`21.
`Defendant admits that venue is proper in this forum. Paragraph 21 otherwise sets
`forth legal conclusions to which no response is required. To the extent a response is required,
`Defendant denies the remaining allegations in Paragraph 21.
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`DEFENDANT PINTEREST’S ANSWER TO TAC
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`-3-
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`Case 5:20-cv-05290-EJD Document 102 Filed 12/30/24 Page 5 of 13
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`ALLEGATIONS COMMON TO ALL CLAIMS
`22.
`Defendant admits that: it enables Pinterest users to create boards to which they can
`save images and videos; users can have multiple boards; and users can browse, share, and in some
`cases react to other users’ boards, saved images, and videos. Defendant denies the remaining
`allegations in Paragraph 22.
`23.
`Responding to the first sentence, Defendant admits that it hosts user-saved (or
`“organic”) Pins, some of which advertisers use as advertising (or “promoted”) Pins. Responding
`to the second sentence, Defendant admits that it hosts Pins on Pinterest servers. Responding to the
`third sentence, Defendant admits that its service has a search function. Defendant denies the
`remaining allegations in Paragraph 23.
`24.
`Defendant admits that Pinterest’s notification messages hyperlink to images that
`other Pinterest users have saved to Pinterest’s service and that reside on Pinterest’s
`servers. Defendant denies the remaining allegations in Paragraph 24.
`25.
`Defendant admits that all notification messages sent by Pinterest hyperlink to
`images that other Pinterest users have saved to Pinterest’s service and that reside on Pinterest’s
`servers. Defendant denies the remaining allegations in Paragraph 25.
`26.
`Defendant admits that advertisements are shown on certain surfaces on its
`service. Defendant denies the remaining allegations in Paragraph 26.
`27.
`Defendant admits the allegations in Paragraph 27.
`28.
`Defendant denies the allegations in Paragraph 28.
`29.
`Defendant denies the allegations in Paragraph 29.
`30.
`Defendant admits that it generates revenue from advertising. Defendant denies the
`remaining allegations in Paragraph 30.
`31.
`Defendant denies the allegations in Paragraph 31.2
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`2 To the extent Plaintiff incorporates images and captions into his allegations, as it does here
`and elsewhere in the TAC, Defendant states that such material fails to include sufficient identifying
`information (e.g., URLs) and thus leaves Defendant without knowledge or information sufficient
`to form a belief about the truth of those images and captions. On that basis, Defendant denies any
`allegations or assertions made by way of the images unless stated otherwise.
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`DEFENDANT PINTEREST’S ANSWER TO TAC
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`-4-
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`CASE NO.: 5:20-CV-05290-EJD
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`Case 5:20-cv-05290-EJD Document 102 Filed 12/30/24 Page 6 of 13
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`32.
`There are no allegations to answer in this paragraph because the allegations pertain
`solely to Harold Davis, who has been dismissed from the action with prejudice. ECF No. 100 at
`7. To the extent a response is required, Defendant lacks knowledge or information sufficient to
`form a belief about the truth of the allegations in Paragraph 32 and, on that basis, denies them.
`33.
`Paragraph 33 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 33.
`34.
`Paragraph 34 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 34.
`35.
`Paragraph 35 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 35.
`36.
`Paragraph 36 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 36.
`37.
`Paragraph 37 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 37.
`38.
`Paragraph 38 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 38.
`39.
`Paragraph 39 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 39.
`40.
`Paragraph 40 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 40.
`41.
`Paragraph 41 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 41.
`42.
`To the extent this paragraph goes toward a claim for removal of copyright
`management information (“CMI”), there are no allegations to answer in this paragraph because
`the Court twice dismissed the CMI-removal claim and Plaintiff subsequently abandoned it. See
`ECF Nos. 39, 73. To the extent a response is required to the first sentence, Defendant lacks
`knowledge or information sufficient to form a belief about the truth of the allegations in the first
`sentence and, on that basis, denies them. The second sentence sets forth a legal conclusion to
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`DEFENDANT PINTEREST’S ANSWER TO TAC
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`-5-
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`CASE NO.: 5:20-CV-05290-EJD
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`Case 5:20-cv-05290-EJD Document 102 Filed 12/30/24 Page 7 of 13
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`which no response is required. To the extent that a response is required, Defendant denies the
`allegations in the second sentence.
`43.
`To the extent this paragraph goes toward a claim for removal of CMI, there are no
`allegations to answer in this paragraph because the Court twice dismissed the CMI-removal claim
`and Plaintiff subsequently abandoned it. See ECF Nos. 39, 73. To the extent a response is
`required, Defendant lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in Paragraph 43 and, on that basis, denies them.
`44.
`To the extent this paragraph goes toward a claim for removal of CMI, there are no
`allegations to answer in this paragraph because the Court twice dismissed the CMI-removal claim
`and Plaintiff subsequently abandoned it. See ECF Nos. 39, 73. To the extent a response is
`required, Defendant lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in Paragraph 44 and, on that basis, denies them.
`45.
`To the extent this paragraph goes toward a claim for removal of CMI, there are no
`allegations to answer in this paragraph because the Court twice dismissed the CMI-removal claim
`and Plaintiff subsequently abandoned it. See ECF Nos. 39, 73. To the extent a response is
`required, Defendant lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in Paragraph 45 and, on that basis, denies them.
`46.
`To the extent this paragraph goes toward a claim for removal of CMI, there are no
`allegations to answer in this paragraph because the Court twice dismissed the CMI-removal claim
`and Plaintiff subsequently abandoned it. See ECF Nos. 39, 73. To the extent a response is
`required, Defendant admits that it endeavors to maintain certain metadata that may accompany
`user-uploaded images. Defendant denies the remaining allegations in Paragraph 46.
`47.
`Defendant denies the allegations in Paragraph 47.
`48.
`Defendant denies the allegations in Paragraph 48.
`CLASS ALLEGATIONS
`49.
`Defendant admits that Plaintiff purports to bring a class action with a subclass of
`“identified professional photographers.” Defendant denies the remaining allegations in Paragraph
`49.
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`DEFENDANT PINTEREST’S ANSWER TO TAC
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`-6-
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`CASE NO.: 5:20-CV-05290-EJD
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`Case 5:20-cv-05290-EJD Document 102 Filed 12/30/24 Page 8 of 13
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`50.
`Defendant admits that Plaintiff purports to reserve the right to redefine the class
`and/or subclass. Defendant denies the remaining allegations in Paragraph 50.
`51.
`Paragraph 51 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 51.
`52.
`Paragraph 52 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 52.
`53.
`Paragraph 53 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 53.
`54.
`Paragraph 54 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 54.
`55.
`Paragraph 55 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 55.
`56.
`Paragraph 56 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 56.
`57.
`Paragraph 57 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 57.
`58.
`Paragraph 58 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 58.
`CAUSE OF ACTION
`Infringement of Copyright On Behalf of Plaintiffs, the Class, and Subclass
`59.
`Defendant reiterates its responses to the preceding paragraphs of this Answer to the
`TAC as if fully set forth herein.
`60.
`Defendant lacks knowledge or information sufficient to form a belief about the truth
`of the allegations in Paragraph 60 and, on that basis, denies them.
`61.
`Defendant denies the allegations in Paragraph 61.
`62.
`Paragraph 62 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 62.
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`DEFENDANT PINTEREST’S ANSWER TO TAC
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`-7-
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`Case 5:20-cv-05290-EJD Document 102 Filed 12/30/24 Page 9 of 13
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`63.
`Paragraph 63 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 63.
`64.
`Paragraph 64 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 64.
`65.
`Paragraph 65 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 65.
`66.
`Defendant admits that Plaintiff purports to seek the relief identified in Paragraph
`66. Defendant denies the remaining allegations in Paragraph 66.
`67.
`Paragraph 67 sets forth legal conclusions to which no response is required. To the
`extent that a response is required, Defendant denies the allegations in Paragraph 67.
`PRAYER FOR RELIEF
`This Section contains allegations that are legal conclusions to which no response is
`required. To the extent a response is required, Defendant denies that Plaintiff is entitled to the
`judgment and relief requested or to any other relief.
`AFFIRMATIVE AND OTHER DEFENSES
`Pursuant to Rule 8(c) of the Federal Rules of Civil Procedure, Defendant asserts the
`following affirmative and other defenses and does so on information and belief as to the actions of
`others. Defendant does not concede that it bears the burden of proof or persuasion on any of these
`defenses. Defendant reserves the right to assert additional defenses in the event that discovery or
`further investigation demonstrates that any such defense is appropriate or applicable. In particular,
`given that Plaintiff has failed to identify with specificity the allegedly infringing activity for the
`image that it contends is at issue in this case, Defendant is unable to fully assess the defenses that
`may be available to it regarding any particular infringement claim.
`FIRST DEFENSE
`(Failure to State a Claim)
`Plaintiff’s TAC fails to state a claim for copyright infringement to the extent that Plaintiff
`purports to be asserting an infringement claim based on copyrighted works that it has not actually
`identified in the TAC or works that have not been registered with the Copyright Office. Further,
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`DEFENDANT PINTEREST’S ANSWER TO TAC
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`-8-
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`Case 5:20-cv-05290-EJD Document 102 Filed 12/30/24 Page 10 of 13
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`the TAC fails to state a claim of direct infringement because Plaintiff fails to adequately allege
`volitional conduct by Defendant and fails to plead facts demonstrating distribution or display with
`respect to images that appear on users’ computer screens that are merely framed/in-line linked.
`SECOND DEFENSE
`(Digital Millennium Copyright Act (DMCA) Safe Harbors)
`Plaintiff’s claim is barred in whole or in part because Defendant is protected by one or
`more of the DMCA Safe Harbors set out in 17 U.S.C. § 512. Most notably, Defendant is not liable
`for any alleged infringement that arises by reason of the storage at the direction of users of material
`residing on its service. See 17 U.S.C. § 512(c). Nor is Defendant liable for any alleged
`infringement that arises by reason of its referring or linking users to an online location containing
`infringing material or infringing activity, by using information location tools, including a directory,
`index, reference, pointer, or hypertext link. See 17 U.S.C. § 512(d).
`THIRD DEFENSE
`(License)
`Plaintiff’s claim is barred in whole or in part by licenses, consents, or permissions that
`Plaintiff and/or its agents have granted to Defendant and/or to third parties who in turn have
`granted licenses to Defendant. For example, if Plaintiff and/or its agents have granted third parties
`permission to pin the work at issue to Defendant’s service by posting the work to Plaintiff’s and/or
`third-party websites with a “Pin it” button that enables sharing content on Pinterest, as it has with
`many of Plaintiff’s photographs, then Plaintiff and/or its agents have granted Defendant license(s)
`to the work under Defendant’s Terms of Service.
`FOURTH DEFENSE
`(Fair Use)
`The activity that Plaintiff identifies as infringing is not in fact infringing to the extent it
`constitutes a fair use of the underlying copyrighted material. See 17 U.S.C. § 107.
`FIFTH DEFENSE
`(Estoppel)
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`DEFENDANT PINTEREST’S ANSWER TO TAC
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`-9-
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`Case 5:20-cv-05290-EJD Document 102 Filed 12/30/24 Page 11 of 13
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`Plaintiff’s claim is barred in whole or in part by the doctrine of estoppel. Defendant has
`relied on representations from Plaintiff or his representatives or agents about Defendant’s
`authorization to use all or portions of the copyrighted works at issue. For example, Plaintiff and/or
`those acting at its direction engaged in activities including interacting with the Pinterest platform
`so as to generate emails and app notifications from Pinterest that are alleged to constitute
`infringement.
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`SIXTH DEFENSE
`(Unclean Hands)
`Plaintiff’s claim is barred in whole or in part by the doctrine of unclean hands. Plaintiff
`and/or those acting on its behalf have taken affirmative steps to facilitate the conduct about which
`Plaintiff complains to manufacture a claim in this litigation. For example, Plaintiff and/or those
`acting on its behalf have interacted with the Pinterest platform, such as by conducting searches for
`Plaintiff’s works, to generate user-activity profiles that are more likely to result in Plaintiff’s works
`being recommended to their accounts. Plaintiff thus caused and exacerbated the supposed
`infringement that is the subject of this litigation. Plaintiff also has unclean hands to the extent it
`failed to preserve, and thus spoliated, evidence (e.g., Plaintiff’s personal website with its
`copyrighted work) that goes to the core of Defendant’s defenses and for which Defendant has
`already served discovery.
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`SEVENTH DEFENSE
`(Failure to Mitigate)
`Plaintiff’s claim is barred in whole or in part because Plaintiff failed to mitigate Plaintiff’s
`damages, if any. For example, Plaintiff was well aware of the ability to request that Defendant
`remove any allegedly infringing content using Defendant’s DMCA takedown process. To the
`extent Plaintiff failed to use that process with respect to specific allegedly infringing material on
`the Pinterest service, and to the extent Plaintiff refused to provide information necessary to identify
`allegedly infringing material when Defendant explicitly requested that information, Plaintiff has
`failed to mitigate the damages that it claims to have suffered.
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`DEFENDANT PINTEREST’S ANSWER TO TAC
`
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`-10-
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`Case 5:20-cv-05290-EJD Document 102 Filed 12/30/24 Page 12 of 13
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`EIGHTH DEFENSE
`(Statute of Limitations)
`Plaintiff’s claim is barred in whole or in part by the applicable statute of limitations, which
`requires Plaintiff to have brought its claim within three years after they had accrued. See 17 U.S.C.
`§ 507(b).
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`NINTH DEFENSE
`(Substantial Non-Infringing Use)
`Plaintiff’s claim is barred in whole or in part by the doctrine of substantial non-infringing
`use, although Defendant submits that Plaintiff bears the burden of proving the doctrine’s
`inapplicability.
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`TENTH DEFENSE
`(Contract Provisions)
`Plaintiff’s claim is barred in whole or in part by the provisions of Pinterest’s Terms of
`Service, which Plaintiff agreed to be bound by. For example, Pinterest’s Terms of Service impose
`limitations of liability for any use of Plaintiff’s content uploaded by third parties.
`ELEVENTH DEFENSE
`(Waiver)
`Plaintiff’s claim is barred in whole or in part by the doctrine of waiver. For example,
`Plaintiff’s claim is barred to the extent that Plaintiff and/or those acting at its direction posted the
`work to Plaintiff’s and/or third-party websites that embed “Pin it” buttons to enable sharing content
`on Pinterest.
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`TWELFTH DEFENSE
`(Putative Class Members)
`Defendant alleges that this lawsuit cannot proceed as a class action. Should the Court
`determine otherwise, Defendant may have numerous affirmative defenses and counterclaims
`against individual members of any alleged class, and accordingly, Defendant reserves its right to
`assert those affirmative defenses and counterclaims in a timely fashion.
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`DEFENDANT PINTEREST’S ANSWER TO TAC
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`-11-
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`CASE NO.: 5:20-CV-05290-EJD
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`Case 5:20-cv-05290-EJD Document 102 Filed 12/30/24 Page 13 of 13
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`PRAYER
`WHEREFORE, Defendant respectfully requests the following relief:
`A.
`A judgment in favor of Defendant denying Plaintiff all relief requested in its TAC
`in this action and dismissing Plaintiff’s TAC with prejudice;
`B.
`That Defendant be awarded its costs of suit, including reasonable attorney’s fees;
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`and
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`C.
`That the Court award Defendant such other and further relief as the Court deems
`just and proper.
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`Dated: December 30, 2024
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`DEMAND FOR JURY TRIAL
`Defendant demands a trial by jury on all issues so triable.
`Respectfully submitted,
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`By: /s/ David H. Kramer
`David H. Kramer
`dkramer@wsgr.com
`Thomas R. Wakefield
`twakefield@wsgr.com
`Andrew T. Kramer
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`akramer@wsgr.com
`Qifan Huang
`qhuang@wsgr.com
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`Counsel for Defendant PINTEREST, INC.
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`DEFENDANT PINTEREST’S ANSWER TO TAC
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`-12-
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`CASE NO.: 5:20-CV-05290-EJD
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