Venture-capital firm Kleiner Perkins Caufield & Byers filed a response to Ellen Pao's allegations of sexual discrimination by the company in California state court on Wednesday, "vigorously" denying those allegations and requesting Pao's lawsuit be dismissed. The firm argued that Pao's failure to advance within the company's ranks was a result of her own performance, not sexual discrimination on the part of the company as Pao alleged.