- 5 - A B C A 12. On 23 June 2023, to comply with [2] of the Service Order, DOJ served copies of, inter alia, the documents referred to therein on OTC. B C In the same letter, DOJ queried whether Ms Chow, as an “Intended D E F G H I Defendant”, had complied with relevant procedures such as the filing of an Acknowledgement of Service. 13. On 26 June 2023, OTC wrote twice to DOJ, as solicitors acting for “Intended Defendant CHOW HANG TUNG”, requesting further documents. 14. D E F G H On 27 June 2023, DOJ wrote to OTC. Paras 2 and 8 of the I letter stated as follows [emphasis added] : J K L M N O P Q R S J “2. Your letter has not made clear how Ms Chow Hang Tung whom you represent falls within the description of the Defendant in the Writ, namely persons conducting themselves in any of the acts prohibited under paragraphs 1(a)-(d) of the Indorsement of Claim. In particular, it is unclear whether Ms Chow claims that she is or has been broadcasting etc. the Song (as defined in the Indorsement of Claim) with intend to incite secession or with a seditious intend or with intent to insult the national anthem, or whether she is or has been assisting or authorizing etc. others to do so. We therefore do not accept that Ms Chow has the necessary locus to join or participate in the proceedings as an Intended Defendant as you stated in your letter. … 8. We look forward to receiving your client’s grounds of opposition by 30 June 2023. Further, please note that we are liaising with you and serving papers on you solely in the interests of saving time and costs despite: (i) your client has not demonstrated how she qualifies as an Intended Defendant; and (ii) the procedural irregularity that your client has not filed any Acknowledgment of Service or complied with paragraph K L M N O P Q R S T T U U V V