“My job now is to preserve the procedural path so that the merits can be heard later.”

If Judge Furman asks:

“Is mphasis.eu still active?”

No, Your Honor. I have unpublished and disabled the site. It contains no content and no downloadable materials, and I am not operating it. I took that step to ensure full compliance.

Stop.

If Plaintiff says:

“The domain still exists.”

Your Honor, I understand the concern. The domain is inactive and contains no content. I am not operating it.

Stop.

If Judge Furman asks:

“Why didn’t you remove the domain earlier?”

Your Honor, I understood the Order to prohibit disparagement and misuse of confidential information. My focus was on ensuring that no confidential material was used and that anything posted was limited to public court filings.

I did not initially appreciate that the continued existence of the domain name itself, even without active content, could be viewed as noncompliant.

Once I recognized that concern, I disabled the site to eliminate any ambiguity and ensure full compliance.

Stop.

If Plaintiff says:

“He only disabled it after we filed ECF 506.”

Your Honor, once the concern was clearly raised in the record, I took prompt steps to disable the site to ensure compliance. My actions reflect correction, not defiance.

Stop.

If Judge Furman presses:

“So you only acted after they filed 506?”

Your Honor, I acted once it became clear that the continued existence of the domain itself could be viewed as noncompliant. My intent was not to violate the Order, and once I recognized that concern, I corrected it.

Stop.

Harder Version:

Judge: “It’s difficult to imagine clearer language. Why shouldn’t I find that you knowingly violated it?”

Your Honor, I understand how it reads. My focus was on ensuring that no confidential information was used and that any materials were limited to public court filings. I did not initially appreciate that the continued existence of the domain name itself, even without active content, could be viewed as noncompliant. Once that concern was clearly raised, I disabled the site to ensure full compliance.

Stop.

If he asks:

“Why should I believe this won’t happen again?”

Your Honor, I understand the seriousness of the Court’s authority. I have disabled all domains using Mphasis or QBE. I will comply strictly with the Court’s Orders going forward.

Stop.