Affirmative defenses shows the direction they are going to take this.

response to claim is typical in any civil suit, when Kbm files their response it will most likely be the same deny, deny , deny. But it isn't till we get to the affirmative defenses that we see what is being alleged by hjoe. Market manipulation, fraud, Usary, unclean hands.
Unclean hands is most likely referring to the Kramer brothers curt a convicted criminal is barred from any sec transactions and is using his brother as a front at KBM. There's a lot of meat here.