In the District Court of the United States, for the Eastern District of Pennsylvania, the United States of America, petitioner, vs. Motion Picture Patents Company, et al., defendants (1913)

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916 Kleine's Answer. 1 1882, pages 909 to 911, inclusive, published at Paris, France, in 1882. An article contained in the same publication, vol. 107, October 15, 1888, pages 607 to 609 inclusive. An article contained in the same publication, vol. 107, for October 29, 1888, pages 677 and 678. An article contained in the same publication, vol. Ill, for November 3, 1890, pages 626 to 629 inclusive. An article contained in Wilson's "Quarter Century in Photography," page 493, published at New York, N. Y., in 1887. 2 XVI. This defendant, further answering on information and belief, says that said reissued letters patent No. 12,192 are void and of no force and effect for the reason that the said Edison was not the original or first inventor or discoverer of the alleged improvement therein described and claimed, or of any substantial and material parts thereof, and that the same was known to and used by others prior to any invention thereof by said Edison as follows, to wit: At San Francisco, Cal., Brooklyn, N. Y., and elsewhere within the United States, by Edward J. Muybridge, who resides at San Francisco, Cal. At Brooklyn, N. Y., and elsewhere within the United States, by W. G. Levison, who resides at Brooklyn, N. Y. At Orange, N. J., and elsewhere within the United States, by William K. L. Dickson, who is now residing at London, England. At Philadelphia, Pa., and elsewhere within the United States, by James W. Bonta, who resides at Philadelphia, Pa.; and others whose names and addresses are not now known to this defendant, but which this defendant prays leave to set up by an amendment to this answer when it shall have ascertained the same. XVII. This defendant, further answering on information and belief, says that said reissued letters patent No. 12,192 are void and of no force and effect because the alleged improvement attempted to be patented thereby did not, at the date of the said reissued letters patent, or at the date of the said original letters patent, or at the date of