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... Cinemark's primary contention on appeal is that, under the totality of the circumstances, its
transactions with film distributors for the use of motion picture film reels are not taxable events
because they involve intangible, intellectual property rights rather than tangible personal ...
... The complaint defined "the Property" as "the software as well as [a website and associated domain
names], the source code, the object code, all software documentation, [certain marketing materials]
for which it ha[d] paid and the associated intellectual property rights." In their ...
... being stolen. Indeed, even in its appellate brief, plaintiff continues to maintain that
its claims arise from defendants' "failure to transfer title to all of the intellectual property
as represented in the parties' Asset Purchase Agreement.". ...