This CEN case document is a three-page Carter-Ruck letter sent on behalf of Central European News and Michael Leidig to Alan White at BuzzFeed on 22 April 2015, three days before publication of BuzzFeed’s article about CEN. The letter responds to BuzzFeed’s emails of 15 and 20 April, saying the original response deadline was unreasonable given the scope of the questions and the age of some of the stories, and noting that BuzzFeed had also contacted Mirror Group Newspapers about CEN-supplied stories. Its significance is that it sets out, before publication, the core objections CEN later made to the BuzzFeed article: that the allegations were highly defamatory, likely to cause serious reputational harm, and had already been put to two of CEN’s customers, Mirror Group Newspapers and Associated Newspapers, “ostensibly in the guise of an enquiry” about stories originating from CEN. The letter states that CEN is BuzzFeed’s main competitor for viral news content in the UK market and says CEN would not provide detailed information about its sources and practices to a competitor. It accuses BuzzFeed of fishing for information and says the proposed publication appeared calculated to damage CEN’s business. The letter also denies absolutely that CEN makes up false stories or fabricates quotes, says CEN relies on trusted contributors, and argues that BuzzFeed’s questions did not provide evidence or “proof” of fabrication. It makes the important numerical point that BuzzFeed had subscribed to the CEN newsfeed since January 2014 and had received more than 8,000 stories, yet had identified only 17 items about which it raised questions, which Carter-Ruck argued could not reasonably establish a “pattern” of fabrication. The letter also challenges BuzzFeed’s claimed public-interest framing, saying that if the true subject was the pressure of running an online news organisation in the viral internet age, BuzzFeed itself was the obvious place to start, especially given then-recent criticism of BuzzFeed over plagiarism, copyright infringement and the deletion of articles critical of advertisers. It further says BuzzFeed had been disingenuous in its early approach to Leidig by presenting the intended article as being about CEN’s expansion and the challenges of reporting in the digital age, when the later questions made clear that this was not the true purpose of the enquiry. The final section deals briefly with Journalism Without Borders, explaining that CEN had already provided contacts for financial enquiries, that Leidig was vice-chair of the National Association of Press Agencies with responsibility for special projects, and that JWB had not raised significant sums but remained a project in which CEN believed. The document is important because it shows that before publication BuzzFeed had already been warned about the competitor issue, the reputational and commercial damage, the weakness of treating 17 queried stories out of more than 8,000 feed items as a pattern, the danger of relying on online debunking rather than proper investigation, and the potential unfairness of approaching CEN’s customers with damaging allegations before publication.