UL's brief is self-explanatory and nicely set out, and essentially says that Ryan's
complaint discloses no viable claim and should, therefore, be dismissed.
In a nutshell, it says:
- that Ryan's complaint discloses no statutory basis for any of the claims made by Ryan;
- that UL is not a government entity, (thus the first amendment and related claims are not sustainable);
- that Ryan has not pleaded the requisite elements to make out any of his claims;
- that UL was entitled to fire him for his sending the letter to NIST containing many false or unsubstantiated assertions" and "baseless assertions" and "incredible and unsupported claims" because he misrepresented his opinions as that of the company;
- that Ryan was an "at will" employee; and
- that Ryan cannot, in the circumstances, bring his dismissal within the narrow exception to "at will" termination, namely "public policy exception."