Exhibit 3 

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DECLARATION OF DR. DANIEL ROGERS

1. My name is Dr. Daniel Rogers. I am a resident of the state of New York. I am 

the Co-founder and a Director of the Disinformation Index Ltd. (“GDI”). I have personal 

knowledge of the facts set forth herein. I have also reviewed the complaint and preliminary 

injunction in The Daily Wire, LLC v. Department of State, Case No. 6:23-cv-00609 (E.D. Tex.) 

(Dkt. 1 and 11), with special focus on allegations related to GDI. 

2. GDI is a not-for-profit company based in London, United Kingdom. The main 

goal of GDI’s work is to provide independent, neutral disinformation risk data to digital 

advertisers around the world, enabling them to make more informed brand safety decisions 

regarding their open web programmatic advertising purchases. GDI uses both human review and 

artificial intelligence to assess disinformation risk and provide risk ratings to brands and 

advertising partners to aid in their decision making. Our work is analogous to the role bond 

ratings agencies play in informing bond traders on purchase decisions, and is in keeping with the 

principles of both free markets and free speech.

3. In 2021, the U.S. State Department’s Global Engagement Center collaborated 

with various European governments and international organizations, including the North Atlantic 

Treaty Organization (NATO), to sponsor the U.S.-Paris Tech Challenge. The challenge sought 

to fund organizations based in the European Economic Area and the United Kingdom to advance 

the development of technologies that combat disinformation and propaganda globally. Only 

organizations based in those locations were eligible to apply. Winners received a subgrant from 

Park Advisors, a GEC grantee.

4. GDI participated in the U.S.-Paris Tech Challenge and was selected as one of 

three finalists. As part of that selection, GDI received a $100,000 award to help fund the 

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development of our technology. The agreed-upon objective for this funding was to expand 

GDI’s disinformation risk measurement to a broader set of countries in East Asia and Europe, 

within China and Russia’s spheres of influence, to enable advertisers in those markets to make 

similarly informed brand safety decisions about where they were buying ads, in line with global 

geopolitical strategic aims of the United States. GDI previously had established this technology, 

which originally operated in six European languages, but the goal of the grant was to expand it

into additional languages associated with the Chinese and Russian spheres of influence. The 

objective of the grant did not include expanded disinformation risk measurement in the United 

States, and GDI has a strict policy not to use funding from any government around the world to 

assess their own media markets, in accordance with principles of free speech and free press. 

5. GDI used the funding from the U.S.-Paris Tech Challenge to advance the artificial 

intelligence technology we had previously created to recognize additional languages and to train 

GDI classifiers on local and culturally relevant adversarial narratives in those regions for use in 

risk measurement. Specifically, GDI expanded its risk measurement to six new languages -

Chinese, Japanese, Korean, Vietnamese, Russian, and Ukrainian. The GDI team also used 

funding from the U.S.-Paris Tech Challenge to train the program with specific disinformation 

content identified in those languages to help improve the model’s performance in translating that 

type of content at scale. The work was successful and GDI was able to greatly increase the 

precision of its translations for those six languages. 

6. The complaint and preliminary injunction include several incorrect statements 

about how GDI used the funds from the U.S.-Paris Challenge. For example, the complaint 

states, “the U.S.-Paris Challenge awarded cash prizes to GDI which blacklisted Media Plaintiffs” 

(¶ 126). This is not true for several reasons. First, the complaint defines “GDI” as the 

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Disinformation Index Inc. (¶3). Disinformation Index Inc. is the United States-based affiliate of 

GDI, which did not receive any funding from the U.S.-Paris Tech Challenge. The funding from 

the U.S.-Paris Tech Challenge was awarded to the London based company Disinformation Index 

Ltd. Disinformation Index Inc. had no role in the receipt or use of funding from the U.S.-Paris 

Tech Challenge. Second, no portion of the funds that GDI received from the U.S.-Paris 

Challenge was used to “blacklist” any U.S. entity. GDI provides data to advertisers around the 

world to inform their brand safety risk decisions – GDI has neither the capability nor remit to 

“blacklist” any media entities. All buying decisions are made by the advertising buyers 

themselves, in accordance with free market principles. Third, the $100,000 U.S.-Paris Tech 

Challenge award was used to add language capabilities in six languages, to my knowledge, in 

which neither Media Plaintiff publishes content, for locations outside of the United States. 

7. The motion for a preliminary injunction also states that “GDI used some of the 

$100,000 State Department award to fund the infrastructure supporting the Dynamic Exclusion 

List” (p. 13). This is also not true. GDI’s Dynamic Exclusion List was not funded by the State 

Department or any State Department-affiliated entity. GDI’s infrastructure costs were borne 

entirely out of other, private sources of funding. Additionally, GDI’s Dynamic Exclusion List is 

a product of the U.S. entity, Disinformation Index, Inc.; as described above, the U.S.-Paris Tech 

Challenge award was awarded to Disinformation Index, Ltd., in the United Kingdom.

8. The complaint incorrectly implies a connection between GDI’s Dynamic 

Exclusion List and our 2022 Disinformation Risk Assessment Report for the United States. 

GDI’s Dynamic Exclusion List is a non-public source that is updated monthly to capture 

publications with a high risk for disinformation around the world. GDI’s Disinformation Risk 

Assessment Report for the United States was published publicly in November 2022 and 

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reviewed sixty-nine U.S. news sites, scoring them for the degree to which they presented a risk 

of disinforming their readers. In that report, GDI included a list of the 10 least risky and the 10 

most risky of only those sixty-nine news sites manually reviewed for the purposes of that report. 

The report was completely independent of the Dynamic Exclusion list and was supported by 

private funds; there is no correlation between risk as identified in the report and any site’s 

inclusion in or exclusion from GDI’s Dynamic Exclusion List. 

9. The complaint also discusses Disinfo Cloud. To my knowledge, GDI’s 

technology was never included on the Disinfo Cloud platform. The entire Disinfo Cloud project 

appears to have been discontinued in 2021. 

10. The full extent of GDI’s connection to Disinfo Cloud, to my knowledge, consists 

of GDI’s brief mention in a blog post discussing the winners of the U.S.-Paris Tech Challenge, 

which has since been taken offline, and a retweet on the Disinfo Cloud Twitter account of GDI’s 

announcement of a partnership with NELEZ. (Complaint, ¶ 87). 

11. GDI has not been involved with the Silicon Valley Engagement initiative outlined 

in the complaint, nor does GDI have, or has ever had, any relationship with Becera.

12. Entirely independent of the U.S.-Paris Tech Challenge grant, GDI received a

grant from the National Endowment for Democracy (NED) to perform specific media market 

analyses in India, Turkey, Thailand, Bangladesh, Columbia, Malaysia, Mexico, Nigeria, the 

Philippines, Tanzania, Ghana, Algeria, Tunisia, Morocco, Taiwan, and Vietnam, as well as the 

expansion of our translation capabilities to four non-roman alphabet languages, including 

multiple dialects of Arabic. To my knowledge, neither Media Plaintiff publishes content in any 

of those countries, nor in any of the aforementioned non-European languages.

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13. Also unrelated to the U.S.-Paris Tech Challenge, GDI was invited, prior to the 

Challenge and the grant from NED, to consult with the World Federation of Advertisers as part 

of their Global Alliance for Responsible Media (GARM) effort, which was created by brands 

such as Procter and Gamble and others to devise industry wide brand safety standards across 

multiple categories. None of our work providing subject matter expertise to the GARM 

community was supported by any funds from the State Department; not only would it go against 

our aforementioned policies and specific statements of work, but it also occurred before the U.S.-

Paris Tech Challenge award was issued.

I declare under penalty of perjury that the foregoing is true and correct.

Executed in the state of New York on March 14, 2024.

___________________

 Dr. Daniel Rogers

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