With no explanation, chose the best option from "A", "B", "C" or "D". based on the lack of any evidence that the defendant copied an entire category of the plaintiffs directory, but explaining that a finding of infringement would succeed if the defendant had exactly duplicated a substantial designated portion of the plaintiffs directory such as all of the listings of professionals such as medical doctors, lawyers, accountants, engineers, and architects). To the extent that Wiggs’s analysis of the directories was misleading, it is an elementary rule on summary judgment that the burden shifted to Donnelley to produce its own comparative analysis of the published directories in order to rebut the undisputed evidence of substantial similarity in Wiggs’s affidavit. See United States v. Four Parcels of Real Property, 941 F.2d 1428, 1438 (11th Cir.1991) (<HOLDING>); Fed.R.Civ.P. 56(e). As a non-moving party

A: holding that to survive a motion for summary judgment a party must make a showing sufficient to establish the existence of an element essential to that partys case and on which that party will bear the burden of proof at trial
B: recognizing that the burden on summary judgment shifts to the nonmoving party once the moving party has met its initial responsibility of showing the absence of a triable issue of fact and that the moving party is entitled to summary judgment if the nonmoving party fails to make a sufficient showing on an essential element of the case
C: holding the moving party must meet its burden by showing  that is pointing out to the trial court that there is an absence of evidence to support the nonmoving partys case
D: holding that the moving party for summary judgment bears the initial burden of demonstrating the absence of a genuine issue of material fact for trial
B.