This memorandum by Harry H. Wise III, Michael Leidig’s New York lawyer, summarises the background to the BuzzFeed article “The King of Bullsh*t News”, the internal BuzzFeed discussions that preceded publication, the evidence obtained through the litigation, and the legal reasons the case did not reach a jury. It argues that BuzzFeed’s article portrayed Michael Leidig and Central European News as fabricators of fake stories and quotes, while BuzzFeed later maintained in court that it had not meant to accuse him personally of fraud. The memorandum is especially relevant because it explains the legal failure of the case as an evidential and procedural issue, not as a finding that BuzzFeed’s allegations were true. Harry Wise identifies the fatal problem as the death of CEN’s Russian correspondent Mladen Dotchev before the lawsuit was filed and the unavailability of a Chinese stringer whose stories were among those discussed in the complaint. Under American libel law, Michael Leidig and CEN had the burden of proving falsity, and the courts held that the absence of those witnesses meant they could not prove the relevant stories had not been falsified. The memorandum also argues that the courts failed to rule properly on the wider “gist” or “sting” of the article: the claim that Michael Leidig and CEN were in the business of making things up. It is a key Source Library document for explaining why the New York case was rejected before trial, why that rejection was not the same as BuzzFeed proving its claims, and why the disclosure material obtained through the litigation became central to the later book.