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Defendants' submissions
10. On the other hand, it is submitted by Mr. Parag Tripathi, ld. Senior Counsel appearing for Facebook - Defendant No. 1, that no effort has been made by the Plaintiffs to implead the persons whose details have been provided in the BSI. He relies upon the judgments in Google Inc. v Equustek Solutions, Robert Angus and Clarma Enterprises Inc1 (hereinafter, "Equustek-I") and Google LLC v Equustek Solutions Inc., et al. (hereinafter, "Equustek-II")2 and submits that the question as to what Google Inc. v Equustek Solutions, Robert Angus and Clarma Enterprises Inc 2017 SCC 34 (Supreme Court of Canada) Google LLC v Equustek Solutions Inc., et al, United States District Court, Northern District of California, San Jose Division, case No. 5:17-cv-04207-EJD, December 14, 2017 constitutes defamation differs from country to country. For example, in the U.K., the onus is upon the Defendants to show that the content is not defamatory. However, in the U.S., the onus on the Plaintiff in a defamation action is very high. Defamation laws differs from jurisdiction to jurisdiction, and therefore, passing of a global disabling order would be contrary to the principle of comity of Courts and would result in conflict of laws.