would be contrary to free speech standards and may also expose the platforms to legal proceedings. It is averred that such order would lead to libel tourism and forum shopping. 42. It is submitted that active monitoring also cannot be directed. The injunction ought to be restricted to India, and only to the identified URLs. It is further stated that the platforms have complied with the order dated 24th January, 2019. The relevant extract from the written statement reads as under: “4. Without prejudice to the submissions made herein, it is submitted that the Answering Defendants have duly complied with the order dated 24.01.2019 passed by this Hon‘ble Court and the Defendant No. 3 has duly disabled the web links/URLs complained of by the Plaintiffs in the present matter, to the extent that they pertained to YouTube (hereinafter, ―Impugned URLs‖), from the country domain. … 20….It is submitted that the said prayers are untenable and contrary to settled law for the following reasons: (i) To the extent the Plaintiffs seek in its prayers a blanket order to remove ―any other URLs/links containing the Video or part thereof‖ without identifying such videos or specifying their location, the prayer is vague, excessive and incapable of being complied with; (ii) To the extent the Plaintiffs seek in its prayers a blanket direction to block/disable ―any other URLs/links containing the Video or part thereof‖ that defame or disparage the alleged goodwill and reputation of the Plaintiffs, without there being any examination and/or adjudication by the Court on whether each such video is indeed defamatory or disparaging or not, the prayers are contrary to settled law and cannot be granted; CS (OS) 27/2019 Page 36 of 76

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