Re: From Document 78 Filed 04/27/2007
posted on
May 27, 2007 11:28AM
SEVENTH COUNTERCLAIM
(Defamation)
62. e.Digital incorporates by reference the allegations in the preceding paragraphs of this Counterclaim.
63. digEcor’s repeated harassing false statements to e.Digital’s existing and potential customers and business associates constitute the publication of false information about e.Digital.
64. digEcor published its false statements with knowledge that they were false, or without regard to the truth or falsity thereof.
65. digEcor’s false statements were not protected by any privilege.
66. digEcor published its false statements with malice.
67. digEcor made its false statements with knowledge that they would likely damage e.Digital.
68. As a direct and proximate result of digEcor’s false statements, e.Digital has in fact been damaged in an amount to be proven at trial.
