Ray Beckerman shares the reply memorandum in Motown v. Does. The defendant calls RIAA's opposition filing "smoke and mirrors", including the following:

-ignored controlling legal authorities;
-offered no evidence at all;
-made a fabricated contention that Does 1-99 acted together;
-did not dispute the facts contained in the affidavit of programmer Zi Mei;
-attempted to confuse the Court by mixing up "expedited" discovery with "ex parte" discovery;
-cited completely irrelevant authorities;
-frivolously argued that "ex parte" decisions, including the Court's own "ex parte" ruling in this case, should be treated as authoritative precedents;
-frivolously argued that treaties are the same as statutes, and that a treaty should take precedence over the statute which authorized it;
-frivolously argued that the Court was bound by a letter from an employee of the copyright office;
-frivolously argued that merely having files in a shared files folder is in and of itself a copyright infringement; and
-ignored the RIAA's own testimony before the FTC that most people with file sharing software do not even know what files on their computer are subject to being "shared".