Written Statement of Facebook 35. In its written statement, Facebook pleads that it is an intermediary under Section 79 and has no role in initiating transmission, selecting the receiver of any transmission and or selecting or modifying the information contained in the transmissions. It is entitled to protection under Section 79. Reliance is placed on Shreya Singhal (supra). Facebook pleads that it does not have an obligation to proactively monitor the Facebook service in order to block the offending posts. It merely provides a platform to upload the content. It states that the request for global blocking would result in a “conflict of laws situation”, as a global injunction may not be in consonance with the law in other jurisdictions and may jeopardize Facebook‟s status as an intermediary in other jurisdictions. This would be violative of international comity. It states that it is neither the author nor the publisher of third-party content and enjoys immunity under Section 79. In terms of Shreya Singhal (supra), it is only required to act upon a valid Court order or request from an authorized Government agency. It has already taken action in respect of the URLs pointed out by the Plaintiffs. It further avers that it is in compliance with the 2011 Rules and it shall not host, display, modify or publish any information which is covered under Rules 2 and 3 of the 2011 Rules. Written statement of Google LLC and YouTube LLC 36. Google and YouTube have both filed a common written statement. It is averred that Google Plus i.e. Defendant No.4 is not a separate juristic entity, and is only a product which is owned and operated by Google LLC. The said Defendant thus deserves to be deleted. The two platforms claim CS (OS) 27/2019 Page 33 of 76