Here's the complaint:

https://ia803204.us.archive.org/15/items/gov.uscourts.cand.4...

128. The Merits Arbitrator refused to do so. Instead, during a status conference regarding the sanctions motion on April 22, 2026, the Merits Arbitrator held the motion open and stated that if Ms. Wynn-Williams voluntarily appeared at an event, including the Hay Festival, where she knows or should know that her book will be available for sale, or knows or should know that her presence there will likely encourage book sales, then she has likely violated the Interim Award.

129. As Ms. Wynn-Williams's counsel pointed out during the conference, this was an exceptionally broad conception of the scope of the Interim Award one that extended far beyond the text of the Severance Agreement and dramatically increased the burden on Ms. Wynn-Williams. Counsel attempted to clarify that the Merits Arbitrators comment applied only to situations in which the actual event organizer made the book available for sale in connection with Ms. Wynn Williams's appearance, pointing out that the Hay Festival, for example, did not appear to do so but instead simply had a link on the event website to another site run by a separate organization that offered books written by Hay Festival speakers. But, notwithstanding that the details of the Hay Festival appearance had been fully briefed by the parties in their submissions on the sanctions motion, the Merits Arbitrator refused to clarify, stating that there was too much factual granularity for him to give any further guidance and that Ms. Wynn-Williams needed to conform her conduct to what she thinks is appropriate given his endorsement of the Interim Awards vague proscription on promotion

135. In addition, fearful that anything she said could be the basis of another sanctions motion and wishing to protest that constraint on her speech, Ms. Wynn-Williams appeared for the panel but sat in silence for its entire duration, neither speaking nor responding to any question or remark. Ms. Wynn-Williams did not understand that speaking on a panel with Ms. Cadwalladr and Mr. Wu would violate the Interim Award given her intention not to refer to Meta or Careless People, but assumed that Meta would accuse her of endorsing things the other panelists whom Meta believes are some of its known critics might say. Ms. Wynn-Williams also believed that making the alternative decision to cancel her appearance due to the Interim Award would also have drawn attention to Careless People that Meta would interpret as promotion of the book.

136. Notwithstanding that Ms. Wynn-Williams remained silent and did not say anything about Meta or her book and that the Hay Festival removed her book as requested in order to avoid any suggestion of promotion under the Merits Arbitrators guidance, Meta wrote the Merits Arbitrator on June 12, 2026, to request the Merits Arbitrator rule on the sanctions motion immediately and impose additional sanctions based on the Hay Festival.

137. Meta based its request on the fact the other individuals on the panel are, in Meta's view, critics of Meta, suggesting that Ms. Wynn-Williams's mere appearance with those individuals in a public forum was a violation regardless of what she says or whether she speaks at all, and regardless of the fact that she does not control what those individuals say. Meta noted that Ms. Cadwalladr and Mr. Wu responded to Meta's campaign to silence Ms. Wynn-Williams in a manner that Meta found disparaging, alleging that the ensuing controversy resulted in additional sales of Ms. Wynn-Williams's book, notwithstanding that Meta's own actions created that controversy. Meta further suggested that Ms. Wynn-Williams's reaction to her silencing drew attention to herself in a manner that inevitably promoted sales of her book, notwithstanding that Meta's silencing campaign meant that any action Ms. Wynn-Williams took in response including withdrawing from the Hay Festival would have drawn such attention. Meta's exploitation of the Interim Award is thus calculated to make it impossible for her to avoid punishment.

138. Meta's sanctions campaign has been built on sustained surveillance of Ms. Wynn-Williams. Meta's evidentiary submissions in the arbitration have revealed that its representatives attended her public appearances in person, assembled photographs and written records of her movements, and traveled the length of the United Kingdom to do so including making the long journey to rural Wales for the Hay Festival all to document that at each event, Ms. Wynn-Williams said nothing about Meta or her book. In its most recent filing, Meta sought to escalate its coercive surveillance of Ms. Wynn-Williams, asking the Merits Arbitrator to compel Ms. Wynn-Williams to disclose, in advance, a list of her planned public appearances, so that it can continue to monitor where she goes and what she says