20130624 SAC FINAL Redacted for Filing
Case 8:12-cv-00954-AW Document 168 Filed 06/24/13 Page 1 of 73 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND GREENBELT DIVISION METROPOLITAN REGIONAL ) INFORMATION SYSTEMS, INC., ) ) Plaintiff, ) REDACTED ) v. ) Civil Action No. 12-cv-954-AW ) AMERICAN HOME REALTY NETWORK, INC. ) ) ) ) Defendants, ) ) AMERICAN HOME REALTY NETWORK, INC., ) ) Counterclaimant, ) ) v. ) ) METROPOLITAN REGIONAL ) INFORMATION SYSTEMS, INC., ) ) and ) ) NATIONAL ASSOCIATION OF REALTORS, ) ) and ) ) DOEs Nos. 1 – 25, ) ) Counterclaim Defendants. ) ) SECOND AMENDED COUNTERCLAIM Case 8:12-cv-00954-AW Document 168 Filed 06/24/13 Page 2 of 73 Counterclaimant, AMERICAN HOME REALTY NETWORK, INC., (hereinafter, "Counterclaimant" or "AHRN") by its counsel, pursuant to leave of Court by Order of June 10, 2013 [D.E. 160, at 2], hereby files this Second Amended Counterclaim pursuant to Fed. R. Civ. P. 15(a)(1)(B), and complains of counterclaim defendants METROPOLITAN REGIONAL INFORMATION SYSTEMS, INC. AND NATIONAL ASSOCIATION OF REALTORS and DOES Nos. 1-25 (collectively "Counterclaim Defendants," or "Defendants") as follows: 1. Counterclaimant, AMERICAN HOME REALTY NETWORK, INC. ("AHRN") is a corporation organized under the laws of the State of Delaware with its principal place of business at 222 7th Street, 2nd Floor, San Francisco, California, and is a licensed real estate broker in the State of California. 2. Counterclaim Defendant, METROPOLITAN REGIONAL INFORMATION SYSTEMS, INC. ("MRIS") is a corporation organized under the laws of the State of Delaware with its principal place of business at 9707 Key West Avenue, Suite 200, Rockville, Maryland. MRIS, the largest Multiple Listing Service ("MLS") in the United States, began this case with copyright infringement, Lanham Act, and state law tortious conversion and unjust enrichment claims against AHRN.
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