Here is a link to Rossi's lawyers reply to IH's motion to dismiss.It seems to be well written, covering exactly the points raised and putting Vaughn and Darden in a poor position regarding fraud/theft of Rossi's IP.
http://www.e-catworld.com/wp-content/uploads/2016/06/Rossi_et_al_v_Darden_et_al__flsdce-16-21199__0018.0.pdf
