23 June 2016 Herd} Blake Edrmr BuzzFeea 40 Szreet London w" 7E8 Dear make [represent my coHeague,--l -- rmerem or Lycamobrre in France has taken note of your pubhcauan pie 'd chime on 19" June 2016 at 12.019m GMT. 1 am unstructed caregor'rcayy refute your allegations and deny mm the strongest {lemme rarms, No acubn has been brougnt agarnst our cuem and no p'DLeedmgs or any nature have been against cur (lien: mducmg temporary unsure to rraae (reamsmon of guarantees) dearly demonstrazes in am or me proceedmgs which you areege we taken place. Our chem therefore mtends mm We oamgs agai an pamPs for damaga incurred. On readmg your amme, you state ma! u'egedly a French invesflgation renewed on rrom your eartier omrne publrcanons made ember 2015 regarding the UK busmess of Lycamobile. war stage Lycamabue pubmy denied aUegat an; made by auvzreed and that s'atemant remams on your websrte pamcurar 2n the UK :1 was noted that BuuFeed 'nad been prompted to start repunfollowmg an anemp'. by a rrva: te'ecoms compemor Lebara and Charrman, Ratheesan Voganathan, to denigraze Lycamobire. In your words posted on ember 7m, 2015, at 9:15 pm. GMT "mLebara has naw r: orchestrated n; own campa/gn 0f esp/mags [agarnsr LycamobuE/flom May to September 52014;. secret campaign rl/Urmn the bitter battle for a gromng and increasingly burner ufzhe :E/ecoms market . The mvestrgunorr Sta/124305: autumn [2014/ rule and not want r: to become pub/r6 knowr'cc' use, sourzFS say, More go: mm fact about Its :bar it had spied an rryar, said it hired agents to spy on its rival after hearing allegations of impropriety against Lyca. But one source close to the niche firm offarrner Scotland Yard surveillance specialists who did the work said the missrorl was to find dirt that Lebora could use to gain a commercial advantage over its rival. 'The briefing was that Lebam was looking to take Lyca's franchises, said a well-placed source, referring to the shops where the firms sell their prepaid calling cards arid the above background, in your own words, we reasonath seek your confirmation that your recent article in France has not been prompted in any way by Lebara. Please confirm your position immediately. Our Client at the time publicly pointed out that your articles in the UK may have been led by Lebara. it is reasonable therefore to ask this question of your recent articles concerning France. The immediate concern oi our client is that BuzzFeed have misguided the French authorities, whether led by Lebara or not, with misinformation alleging cash transactions and have created a story rather than uncovered one. The reason for that belief is due to the various errors in your article concerning France, Vou have referred to a "huge money laundering system" being investigated by the Parquet National Financier (pup) in France. However, if this anti-money laundering operation relates to a mechanism put in place by the resale or the telephone cards, it does not refer to Lycamobile, Your article has numerous factual errors. Rather than address them line by line, we draw immediate attention to the critical theme throughout of alleged money laundering related to cash transactions. Any proper investigation or Lycamobile's business in France would reveal that it receives no cash payments from any of its business customers. Accordingly, the central theme or alleged money laundering related to cash does not even arise. it is surprising ror an investigative piece to miss this critical tact and instead leave the reader to assume that factually cash is being handled by Lycamobile which it is not, In fact according to the information contained in your article, you appear to raise concerns relating to third parties and suggest that some of these may have been customers of Lycamohile -- which itself is not even confirmed. it there are concerns with third party businesses then the issues you raise are ones generally racing the telecoms sector as you do not state that such parties traded exclusively with Lycamobile. Vour article however avoids any reierence to this and instead seeits to construct a direct link to Lycamohile and infer allegations against Lycamobile. The truth is that no company of the Lycamobile group has ever taken part in any criminal activity of this nature or any nature whatsoever which permits it to categorically reiute any alleged implication. in the coming days, our client will be proactively contacting the police, parquet and magistrate or the Financial Division of the Tribunal de Grands Instance de Paris in this matter and if third parties have indeed been arrested, of which again there is no public evidence then our client shall be pressing for the prosecution of those parties. Regrettably your articles do not seek to make these distinctions clear and i! is noted from many of the comments to your articles that readers are already implying that you are suggesting Lycamobiie is the direct target of arrests and allegations of money laundering and tax fraud. However this is plainly untrue and your articles have been reckless in setting out matters in that way. consequently Lycamobiie has no alternative but to consider legal action against your group for damages We also require disclosure from you as to whether at any stage you have been approached by Lebara in anyjurisdiction, Our Client has already noted that whereas your own articles have not received 5 Significant number of comments onii'rie, instead, staff at Lebara internationaiiy have been active on social media to upload and forward your article -- indicating their corporate support and interest in propagating your story. Vou are no doubt aware that under French lawjudiciai enquiries are strictly confidential and cannot be divulged to third parties. it is alarming therefore that your articles are littered With references to comments purportedly made by public officials which are unable to be verified. These references provide your articles with the impression at credibility when in fact no reader or party affected by the allegations may verify the same. indeed, it such references were made then they are in breach of French due process and if enticed or otherwise iinanciaily motivated in any way by yourselves then thi is actionable in law against you and Buszeediointly and severally These issues and potential causes of action yvrii now therefore he referred to the appropriate French authorities to investigate your own process of enquiry, where it was directed from, who carried out the investigation and which public orficiais were approached and on what terms oi engagement. We make the above referral slnce we note that BuzzFeed UK is not subiect to any UK regulator. We also note that In January, a news agency launched a defamation suit in the us courts against UK, havmg failed to persuade the Site to take down an article which, it was claimed, had damaged the news agenc'fs business, The plaintiff in that matter commented that "was BuzzFeed is not regulated by any independent body, the only alternative was to take legal ("BuzzFeed faces ?11m defamation lawsuit from Viral news agency", Guardian, 27 January 2015) In another news story, in the wake of the establishment of IP50, Lord Puttnam lamented how "digital news sites like BuzIFeed". remain completely unregulated" ("New gress regulation regime is 'buslnESs as usual' says Lord Puttnam", Guardian, 31 March 2015). We look forward to hearing from you immediately as to whether you were approached in any way by Lebara at any point, in anyiurisdiction,