Unfortunately the brief is not searchable, but I'm not sure where David Lam thinks Kik denies that Ted had access to BBM source code. All I see (paragraphs 41-4

Unfortunately the brief is not searchable, but I'm not sure where David Lam thinks Kik denies that Ted had access to BBM source code. All I see (paragraphs 41-43) are some fairly technical defenses to the confidential information claim (RIM didn't allege any breach of confidence, RIM didn't serve Kik with necessary documents, this claim is beyond the court's jurisdiction). Am I missing this somewhere earlier?