Defendant denies every material allegation contained in DirecTV’s complaint. Defendant alleges misjoinder: the defendants have not acted in concert nor do the defendants share a common nexus of facts that would support joinder. The defendant challenges venue: he is a resident of the Northern District and DirecTV “has been previously chastised by the United States District Court for the Central District of Illinois for similar impropriety [in choosing venue].” Defendant sets forth the following additional defenses: 1) DirecTV has no standing because it cannot demonstrate an interception of its product, 2) DirecTV’s claims are barred by the Oklahoma Statute of Limitations, 3) joinder prejudices defendant’s right to a fair trial, 4) DirecTV is guilty of laches and unclean hands, and is not entitled to relief, 5) DirecTV should be collaterally estopped from requesting the same relief against this defendant that it was denied in other lawsuits, 6) even under the facts alleged, DirecTV would not be entitled to the relief sought, 7) the statutory penalties DirecTV seeks are unconstitutionally vague, 8) the damages sought violate the Oklahoma and United States Constitutions because they bear no rational relationship to actual damages, and 9) 18 U.S.C. §§ 1211 and 1212 do not set forth a private cause of action. Defendant asks the court to dismiss the case against him.