Kleiner Perkins Caufield & Byers, the Silicon Valley venture capital firm, filed its legal response Wednesday to the sex discrimination charges made last month by a junior partner, Ellen Pao, sweepingly and specifically denying all the claims.

“K.P.C.B. vigorously denies that it discriminated against plaintiff, retaliated against plaintiff after she complained about harassment or discrimination, or that it violated its obligation to take reasonable steps to prevent discrimination from occurring,” the response says.

Ms. Pao’s suit, which was filed in San Francisco Superior Court a month ago but did not became public until late May, has been roiling Silicon Valley. She argued that Kleiner was in essence an old boys’ club straight out of “Mad Men.” Sexual harassment by a colleague briefly devolved into an affair that resulted in years of discrimination as she struggled unsuccessfully to get ahead, her suit contends.

Kleiner is not only the most prominent venture firm — it took a leading role in financing Amazon and Google — but is also one of the few with a large number of female partners. The lack of women in the venture world is a frequently debated topic in Silicon Valley. If even Kleiner could have discrimination charges brought against it, Ms. Pao’s supporters said, Silicon Valley was an unpleasant place indeed for women.

Shortly after the suit became public in late May, Kleiner indicated it would aggressively fight the charges. John Doerr, the firm’s best-known partner, posted a statement on the Kleiner Web site saying Ms. Pao’s charges had been examined by an outside investigator and found to be without merit. “It is not easy to stand by as false allegations are asserted against the firm,” he wrote.

The firm says in its response that the reason Ms. Pao failed to make senior partner was not discrimination, as Ms. Pao had contended, but because she was not good enough. In 2010, her performance review accused her of being too “territorial,” and said others did not “trust her motivations” and that she had “a sense of entitlement,” the response says.

In one incident that achieved a viral popularity in news accounts of Ms. Pao’s suit, she accused Randy Komisar, a senior Kleiner partner, of giving her a copy of Leonard Cohen’s “The Book of Longing.” The suit said the book “contains many sexual drawings and poems with strong sexual content.” Ms. Pao also said Mr. Komisar had asked her out to a Saturday night dinner, telling her his wife would be out of town. Ms. Pao considered the book and the invitation to be inappropriate in the workplace, her suit says.

The Kleiner response said Ms. Pao “has twisted facts and events.” It said the “profound” Cohen book was written during the author’s five-year stay in a Zen monastery, and so was a natural gift after Ms. Pao and Mr. Komisar, a Buddhist, had a discussion about Buddhism. Ms. Pao, the suit said, had earlier given Mr. Komisar an unnamed book and a small statue of Buddha.

Mr. Komisar’s explanation of the dinner invitation was not addressed in the Kleiner response.

Also unmentioned by name is Ajit Nazre, the junior partner who, Ms. Pao said, began the pattern of harassment after she broke off a brief affair with him. Mr. Nazre left Kleiner early this year. Ms. Pao’s suit says he left in the wake of the internal investigation. Mr. Nazre has not surfaced to give his side.

In separate filings, Kleiner asked for parts of the proceedings to be sealed and for Ms. Pao, who is still working at Kleiner, to be compelled into arbitration as her contract requires. A hearing is scheduled for July 10.

Ms. Pao’s lawyer, Alan Exelrod, did not respond to a telephone call for comment.


This post has been revised to reflect the following correction:

Correction: June 14, 2012

An earlier version of this post misspelled part of the venture firm's name. It is Kleiner Perkins Caufield (not Caulfield) & Byers.