To: scion who wrote (22067 ) 4/8/2012 3:06:19 PM From: scion Read Replies (1) | Respond to of 53574 14. Baldwin lacks knowledge or information sufficient to form a belief regarding whether John Bordynuik, Inc. was started in 2005. Regarding the second sentence of this paragraph, Baldwin admits that Defendant Bordynuik developed hardware that enabled him to recover archived institutional data stored on old magnetic media, but denies that such development was merely “purported.” Baldwin admits that JBI purchased certain assets of John Bordynuik, Inc. in approximately June 2009, but otherwise denies the allegations in the third sentence of this paragraph. Baldwin states that because the phrase “third party transactions” is vague and ambiguous, he lacks knowledge or information sufficient to form a belief regarding the allegation in the fourth sentence of this paragraph and therefore denies the same, except he admits that Defendant Bordynuik was in charge of John Bordynuik, Inc.’s business operations. Regarding the fifth and sixth sentences of this paragraph, Baldwin lacks knowledge or information sufficient to form a belief regarding the allegations and therefore denies the same. Regarding the last sentence of this paragraph, Baldwin admits that JBI has operated a data recovery business since its acquisition of John Bordynuik, Inc., but states that its data recovery business has not been a priority since 2009, due to JBI’s focus on its Plastic2Oil business. Baldwin further admits that in 2009, it began research and development efforts regarding the development of technology that is capable of converting waste plastic into oil with the use of a catalyst. Baldwin otherwise denies the allegations contained in the last sentence of this paragraph. Ronald Baldwin, Jr.'s ANSWER to 1 Complaint Doc 13 PDF file viewer.zoho.com or tinyurl.com SEC COMPLAINT FACTUAL ALLEGATIONS Bordynuik and the Formation of JBI First sentence: 14. In 2005 Bordynuik started a data recovery and restoration company in Canada called John Bordynuik, Inc. Second sentence: He did so after purportedly developing software that would enable him to recover archived institutional data stored on old magnetic media. Third sentence: In time, and through a series of transactions, John Bordynuik, Inc. would become JBI, Inc. (JBI). Fourth sentence: At all times during the existence of John Bordynuik, Inc., and its successor entities, Bordynuik headed the company’s business operations, including third party transactions. Fifth sentence: During its first years of business the company had several large institutional clients that had large volumes of archived data no longer accessible due to the aged mediums on which the data was stored. Sixth sentence: In the process of compiling a massive archive of recovered scientific and research data from these institutions, Bordynuik claimed to have found a catalyst that could be utilized to break down unwashed mixed plastics into liquid hydrocarbons (i.e., oil). Last sentence: Bordynuik continued his data recovery business and began research and development of technology to develop a commercial processor capable of converting waste plastic into oil with the use of the catalyst. Doc 1 PDF file SEC COMPLAINT sec.gov