05/02/2020 Galloway v Frazer & Ors [2016] NIQB 7 (27 January 2016) [25] At this point I must draw attention to the untested evidence which has been filed so far. There has been no attempt by Google to stand over the allegations levelled at the plaintiff by the defendant. The court is genuinely in the dark as to what defences Google might employ if this case goes to trial. [26] In his third affidavit of 21 January 2015 the plaintiff's solicitor made a complaint for the first time about the search results on Google's local search engine and the captions to the videos. On any assessment these were new causes of action, not included in the original summons, nor referred to in any previous iterations of the statement of claim, draft or otherwise, and in respect of which no leave could possibly have been granted by Stephens J. These matters were not before him for consideration. THE PLEADINGS [27] The causes of action are contained in the original Writ of Summons of 9 September 2014 against the defendant, Google Inc, Independent News Media PLC and persons unknown. The writ stated: "The first defendant has pursued a campaign of public vilification and harassment of the plaintiff by way of audio visual publications including publication upon the websites owned and operated by the second and third defendants websites http://www.youtube.com the title "Loyalist Protest under George Galloway" and further upon http://www.belfasttelegraph.co.uk/ the same constituting a breach of the Protection from Harassment (Northern Ireland ) Order 1997. Each of the defendants has further been guilty of publishing libels, slanders and of publishing malicious falsehoods in respect of the plaintiff. The defendants have further committed breach/es of the tort of misuse of private information relating to the plaintiff. As a result of the said breach/es the plaintiffs (sic) have suffered loss and damage." AND THE PLAINTIFFS (sic) CLAIM "(i) An interim and final injunction pursuant to the Protection from Harassment (Northern Ireland) Order 1997 preventing the first, second and third defendants from harassing, pestering, knowing or molesting the plaintiffs whether by publishing, distributing, broadcasting or transmitting any information on the internet or otherwise and requiring the defendant to remove content specified within the schedule attached hereto. (ii) Further, or in the alterative, an interim injunction restraining the defendants, their servants or agents, from publishing, distributing, broadcasting or transmitting any libels, slanders and malicious falsehoods relating to the plaintiff on the internet or otherwise in requiring the defendant to remove contents specified within the schedule attached hereto. (iii) An injunction contra mundum in respect of the republication of the contents specified in the schedule attached hereto. (iv) Damages pursuant to the Protection from Harassment (Northern Ireland) Order 1997. (v) Damages for publication of malicious falsehoods. (vi) Damages for libel and slander. (vii) Damages for breach of the tort of misuse of private information. (viii) Further or other order as deemed appropriate by the court." [28] This Writ of Summons was subsequently amended on 20 November 2014 to claim against Google Inc, Independent News and Google UK Limited and Google Ireland Limited as data controllers for breaches of the "Data Protection Act 1998 ("the 1998 Act") and the EU Data Protection Directive and file:///Users/nerissa/Downloads/Columbia CSV/Galloway v Frazer & Ors [2016] NIQB 7 (27 January 2016).htm 6/26