to-use mechanism” on its website and any user can report a video for violation of his or her rights. In addition, a complaint form can also be filled, which is publicly accessible. Upon receipt of any complaint, the same is reviewed as per YouTube‟s policy and local law of every country, and the same is acted upon. It is submitted that since defamation is a subjective issue, and laws vary from each country, such issues are subject to the local laws of the country where alleged defamation is complained of. It avers that the Courts are the adjudicating authorities to decide whether the alleged content is defamatory. Since YouTube is a dynamic platform, where videos are uploaded every hour, no specific knowledge of the contents of videos can be attributed to YouTube. 40. As per Shreya Singhal (supra), a Court order has to be passed identifying the content as being defamatory, as a claim of defamation is especially hard to judge and only Courts of competent jurisdiction can take a decision on the same. 41. It is pleaded that the plaint does not disclose a cause of action as the ingredients required for a defamation action are not satisfied. It is further pleaded that the injunction sought is vague and broad, as an order is being sought in respect of “other active URLs/links which contain or purport to contain, the infringing or disparaging Video…”. Such an order would be contrary to Shreya Singhal (supra). Further, injunction is being sought “across the globe.” It is pleaded that an order in such terms is beyond the territorial jurisdiction of this Court. Since every Court has its own standards for freedom of speech and expression, the order of the Court cannot be enforced beyond Indian borders. Such an order would expose the Defendants to liability for censoring content in various countries, which CS (OS) 27/2019 Page 35 of 76