Plaintiff operates a website called Community College Review. It received multiple cease and desist letters, which escalated in the severity of their threats, from counsel for certain institutions about which routine, publicly-available data was reported on the website. The claims sounded in copyright and trademark. Our client filed a declaratory judgment action seeking a determination of non-infringement on various grounds, and the defendants filed mirror-image counterclaims. This reply brief further supports the motion to dismiss those counterclaims.