(iii) To the extent that the Plaintiffs seek in its prayers a blanket direction to block/disable videos from its websites ―across the globe‖ which is beyond the territorial jurisdiction of the Hon‘ble Court. It is respectfully submitted that every country has its own standards of Free Speech and Expression – what is lawful in one country may not be lawful in another country and every country has its own standards of Free Speech within its territorial limits. It is pertinent to mention that the said right is not affected by the nature of media use for communication. Therefore, any attempt by the Plaintiffs to seek implementation of orders passed by this Hon‘ble Court (which are undisputably based on the Indian Legal Framework) beyond Indian borders and thus, enforce Indian legal standards of defamation and Free Speech across the world, would outright contradict critical international law presumptions of territoriality and principles of international comity. It is submitted that courts across the world and in India have consistently held that orders passed by them ought to be limited to the territorial jurisdiction of the country. It is respectfully submitted that the Answering Defendants are intermediaries that operate in several countries under the local domain to such countries, in compliance with the respective legal framework of those countries and targeting the local citizenry. Any order for global removal would expose the Answering Defendants to liability for censoring content in a particular country, in contravention to the free speech standards of those jurisdictions.” Written statement of Twitter 43. Twitter claims that it is a social media platform. Further, the description of the Twitter service is pleaded as under: “3. The present suit is not maintainable against the answering Defendant, which makes available the CS (OS) 27/2019 Page 37 of 76

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