Exhibit 2 

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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF TEXAS, TYLER DIVISION

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THE DAILY WIRE, LLC;

FDRLST MEDIA, LLC; and

THE STATE OF TEXAS, by and through its 

Attorney General, Ken Paxton,

Plaintiffs,

-againstDEPARTMENT OF STATE;

GLOBAL ENGAGEMENT CENTER;

ANTONY BLINKEN, in his official capacity 

as Secretary of State;

LEAH BRAY, in her official capacity as 

Deputy Coordinator of the State 

Department’s Global Engagement Center;

JAMES P. RUBIN, in his official capacity as 

Coordinator for the Global Engagement 

Center of the State Department;

DANIEL KIMMAGE, in his official capacity 

as the Principal Deputy Coordinator for the 

Global Engagement Center at the State 

Department;

ALEXIS FRISBIE, in her official capacity as 

Senior Technical Advisor of the Technology 

Engagement Team for the Global 

Engagement Center at the State Department;

PATRICIA WATTS, in her official capacity 

as the Director of the Technology 

Engagement Team at the Global Engagement 

Center at the State Department,

Defendants.

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Case No. 6:23-cv-00609 (JDK)

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DECLARATION OF MATTHEW SKIBINSKI IN OPPOSITION TO PLAINTIFFS’ 

MOTION FOR PRELIMINARY INJUNCTION

I, Matthew Skibinski, hereby declare under penalty of perjury, pursuant to 28 U.S.C. 

§ 1746, as follows: 

1. I submit this declaration in opposition to Plaintiffs’ motion for a preliminary 

injunction. 

2. I am the General Manager of NewsGuard Technologies, Inc. (“NewsGuard”). I am 

a member of NewsGuard’s founding team, having worked at NewsGuard since we launched in 

2018. In my role as General Manager, I help lead NewsGuard’s operations and overall strategy. 

3. NewsGuard was founded by veteran journalists and media executives Gordon 

Crovitz and Steven Brill and launched in 2018 with the aim of providing news consumers with 

detailed assessments of the reliability of news sources they might encounter on the Internet. 

4. NewsGuard is a for-profit organization. For news consumers, it sells a browser 

extension that provides ratings and reviews of the reliability of different news sources next to links 

users encounter on social media sites or search engines. (Users must proactively choose to 

download and subscribe to this browser extension in order to see the ratings.) In addition, as set 

forth on NewsGuard’s website, which also lists all of its outside investors in descending order of 

their ownership interest, NewsGuard’s revenue comes from Internet Service Providers, browsers, 

search engines, social platforms, education providers, advertising agencies, brand safety providers, 

researchers, and others paying to use NewsGuard’s ratings and Nutrition Labels and associated 

data. Put differently, most of NewsGuard’s revenue comes from licensing its data about news 

sources and narratives to private-sector companies. Revenue from the United States government 

or other government entities in Western democracies licensing NewsGuard data about statesponsored disinformation represents a small fraction of NewsGuard’s annual revenues. 

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Nutrition Labels

5. Following extensive consultation with journalists and media consultants, 

NewsGuard developed a methodology for rating the credibility of news sources based on nine 

basic, apolitical criteria of journalistic practice: (1) whether a publication repeatedly publishes 

egregiously false information; (2) whether a publication presents information responsibly, for 

example, by referencing multiple sources including those with first-hand information on a subject 

or event; (3) whether the site transparently acknowledges errors and regularly publishes 

clarifications and corrections; (4) whether a publication distinguishes between news and opinion; 

(5) whether a publication publishes significantly sensationalized or otherwise deceptive headlines; 

(6) whether the site discloses in a user-friendly manner its ownership and/or financing; (7) whether 

paid advertising is clearly labeled as such; (8) whether readers are told who is in charge of deciding 

the content on the site and given a way to contact the site about editorial issues; and (9) whether 

the names and contact information or biographical information about the content creators are 

clearly indicated. These criteria are apolitical and based on widely accepted journalistic standards, 

and are posted publicly on NewsGuard’s website with detailed definitions for each. 

6. Each criterion is worth a certain number of points out of 100, with the criteria 

weighted based on importance. Sites earn the associated points for any criteria they pass, and the 

sum of those points constitutes the site’s trust score on a scale of 0-100. 

7. NewsGuard hired a team of journalists and editors from respected, nonpartisan 

news outlets to research each site, contact sources, review content, and assess whether the site 

passes or fails each of the nine criteria. These findings are captured in a detailed report about the 

site’s rating, which we call a “Nutrition Label.” Nutrition Labels list NewsGuard’s assessment for 

each of the nine criteria and provide detailed explanations and evidence supporting those 

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assessments. Nutrition Labels also include background information on each site’s ownership, 

content, and history. 

8. If a NewsGuard analyst believes that a site may fail one or more of the nine criteria, 

NewsGuard contacts the owner of the website to give them an opportunity to rectify or comment 

on any issues raised in NewsGuard’s review. More than 2,000 publishers have improved their 

NewsGuard score by improving their credibility or transparency practices after engaging with 

NewsGuard’s team through this process. 

9. Nutrition Labels are reviewed, edited, and fact-checked by multiple editors. Before 

being published, each Nutrition Label is shared with the full staff of analysts and the Co-CEOs, 

who each sign off on the rating before it is published. Once the rating is published, all of the 

details—including who at NewsGuard worked on the rating, how determinations were made, how 

each criterion is defined, what evidence supports each criterion determination, and any comments 

from the publication—are shared with the publisher and made available to NewsGuard clients and 

through NewsGuard’s browser extension to NewsGuard users. The entire rating process and 

rationale are, therefore, completely transparent.

10. NewsGuard’s analysts are rigorously apolitical in their review, which is reflected 

in the fact that, according to our data, a nearly equal number of left- and right-leaning websites 

score above 60 points, which is the bar above which we begin to refer to sites as “credible” (even 

if we note some exceptions to this). For example, among “conservative” media outlets, The 

Washington Examiner has 92.5 points and other prominent “conservative” websites such as Fox 

News, The Daily Caller, The Western Journal, Commentary Magazine, The National Review, and 

the website of the Heritage Foundation all are labeled as generally credible in our ratings and 

reviews.

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11. Ratings are updated periodically, typically about once per year, though the precise 

schedule depends on a number of factors.

12. Clients use our ratings in various ways across many different industries. In the 

advertising industry, the most common use case we hear about is from advertisers who are reluctant 

to advertise on news content of any kind for fear of placing their ads on news content that would 

undermine their brand in the eyes of consumers. This concept—that ad placements adjacent to 

certain types of content may tarnish the brand in some consumers’ eyes—is called “brand safety,”

and blocking ad placements on content that brands determine does not match their marketing goals 

(for example, pornographic content or violent content) is a common practice in the advertising 

industry. There are dozens of companies that provide advertisers with different kinds of brandsafety services aimed at ensuring their ads appear on content that match their brand-safety goals, 

and many advertisers use these services to block any advertising placements on any kind of news 

content. Marketers who license NewsGuard for Advertising often instead use our ratings to 

identify news publications that are more likely to present environments that match their brand’s 

content standards—thereby sending advertising dollars to those news websites when the brand 

may otherwise have avoided placing ads on those sites. Other advertisers use our ratings to decide 

which publications might not match their brand-safety guidelines and, thus, should not be targeted 

for advertisements. Different brands and advertisers have different brand-safety standards and 

therefore use our ratings data in different ways. For example, some brands use a bar of 60 points, 

while others may focus on specific criteria a site must pass or use other information we collect, 

such as data about the geographic area or news topics a site focuses on, in deciding where they 

place their ads. In all cases, these decisions are entirely up to the advertiser. 

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13. Due to the politicized media landscape in the United States, it was critical from the

start that NewsGuard’s rating criteria did not favor any political opinion over another. 

NewsGuard’s success is based on trust in its neutrality, coupled with NewsGuard’s commitment 

to the greatest possible transparency and its responsible approach to correcting and updating its 

ratings. 

14. When NewsGuard first published its Nutrition Labels on August 23, 2018, it

included ratings of both The Daily Wire and The Federalist. It continued to expand its number of 

ratings and, by the time it began work on the project funded by the State Department’s Global 

Engagement Center (“GEC”) in late October 2020, NewsGuard had already published ratings 

covering 6,043 domains, representing 97% of online engagement with news in the United States 

at that time. 

15. Today, NewsGuard’s Nutrition Labels cover more than 10,000 websites that

account for 95% of engagement with news in the United States, the United Kingdom, Canada, 

Germany, France, Italy, Austria, Australia, and New Zealand. The ratings are licensed to internet 

service providers, advertising companies, news aggregators, education companies, and social 

media and search platforms, and are made available to individual consumers who can purchase a 

subscription to NewsGuard that includes a browser extension. 

Misinformation Fingerprints

16. In 2020, NewsGuard introduced a new, separate product called “Misinformation

Fingerprints.” Misinformation Fingerprints is a human- and machine-readable catalog of the 

significant false claims circulating online, with a focus on state-sponsored false narratives from 

Russia, China, and Iran. Updated daily, Misinformation Fingerprints is the most comprehensive 

catalog ever created of provably false narratives circulating online. For each false claim, 

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NewsGuard’s journalists provide information from credible, often primary sources explaining why 

the claim is false, along with details about where and when the false claim originated, variations 

of the false claim, and example statements of the claim in multiple languages and from different 

countries. The details of how NewsGuard determined that each claim is false and the precise 

evidence backing up that determination are provided in a written report so that users of the 

Misinformation Fingerprints can make their own determinations as to the claim’s veracity if they 

wish. The Misinformation Fingerprints product does not rate the credibility of news publishers 

and is not used to direct the placement of advertisements.

17. Like the Nutrition Labels, the Misinformation Fingerprints product was created 

independently by NewsGuard; neither GEC nor the Cyber National Mission Force (“CNMF”) nor 

any other government agency was involved in its development. 

18. The Misinformation Fingerprints product is licensed to cyberdefense firms, 

reputation management firms, and researchers, as well as to the defense and intelligence 

communities seeking to understand and to counter hostile information operations by Russia, China, 

Iran, and other governments hostile to the U.S. and its democratic allies. 

19. Some social media platforms and technology companies also license the 

Misinformation Fingerprints data as an independent, transparent third-party source of information 

about false information spreading online. For example, the Ethos Network, a social media app 

targeting Gen-Z users, integrated Misinformation Fingerprints into its user interface, enabling 

users to verify the content of their posts before publishing them.

20. NewsGuard also works with generative AI companies to audit the propensity of 

their models to spread false claims and to better train AI models to provide trustworthy responses 

on prompts related to news topics.

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NewsGuard’s Relationship to the Global Engagement Center

21. On June 10, 2020, NewsGuard applied to the Countering Disinformation 

Challenge, a contest offered jointly by the State Department and the Department of Defense’s 

National Security Innovation Network (“NSIN”). The challenge sought innovative tools to 

identify misinformation and disinformation online in near real time, in response to Russia’s and 

China’s efforts to promote COVID-19 disinformation. On July 31, 2020, NewsGuard learned that 

it was selected as a winner—alongside PeakMetrics, which offers a dashboard for tracking 

mentions of a topic across media channels, and Omelas, which visually maps online information. 

As one of the winners, NewsGuard received $25,000 to conduct a pilot in collaboration with the 

State Department’s GEC and in support of the Department of Defense’s CNMF. 

22. NewsGuard’s work with the GEC and the CNMF was coordinated by Christina 

Nemr at Park Advisors, a small firm that manages public-private projects, particularly relating to 

combating violent extremism and disinformation. 

23. Throughout the Complaint, Plaintiffs falsely describe NewsGuard’s news source 

rating system as “government-funded.” See ECF-1 ¶¶ 4, 119. Not so. NewsGuard’s Nutrition 

Labels ratings product, which included its ratings of the plaintiffs’ websites, was launched in 

August of 2018—two years before NewsGuard first worked with the GEC or received any 

government revenue. 

24. The Complaint also claims that “the State Department Defendants assisted 

[NewsGuard] . . . to further develop and refine their media censorship technology, including 

censorship technology that targets the domestic press and domestic speech.” ECF-1 ¶ 94. This, 

too, is false. NewsGuard’s Nutrition Labels ratings product is not accurately described as “media 

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censorship technology,” and the State Department had no role in developing it, nor did any other 

government agency. 

25. The Complaint states that the technology NewsGuard provided for the project 

“relied on [NewsGuard’s] ratings of news websites, including of American media outlets, such as 

Media Plaintiffs.” ECF-1 ¶ 146. This is false. Instead, from the beginning of the discussions

between NewsGuard, the GEC, the CNMF, and Park Advisors, it was agreed and understood that 

the scope of the project was limited to monitoring foreign state-sponsored sources of 

disinformation—with no focus on domestic news sources. 

26. For example, on October 6, 2020, NewsGuard received an initial draft scope 

document for the pilot from Nemr that stated: “These tests will provide evaluation and 

visualization of trends in state sponsored information and will be a collaboration between three 

companies: PeakMetrics, Omelas, and NewsGuard. During the course of the tests, all three 

companies will take care to minimize data collection on U.S. Persons, focusing primarily on 

tracking foreign adversarial actors and narratives.” (emphasis added).

27. On October 30, 2020, NewsGuard agreed to a Statement of Work for the project 

following discussions with Nemr. This Statement of Work was included in our contractual 

agreement and also made clear that the project was limited only to state-sponsored disinformation

and did not cover information related to domestic news sources. The Statement of Work described 

the “Deliverables to Be Provided by the Service Provider” as follows: 

A series of reports that will help the GEC, USCYBERCOMMAND, and relevant partners 

better understand the origins, content, and spread of state-sponsored disinformation 

campaigns. . . . The focus of the reports will vary based on emerging events but will include 

insights on the following to the extent possible, tracking over time: 1) Which states are 

actively pushing certain narratives ahead of and after the 2020 U.S. elections with an aim 

to undermine the U.S.? (with an initial focus on examining Chinese and Russian state 

media) 2) What are these key narratives being amplified? 3) What broader disinformation 

themes and content are being pushed by China and Russia?

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28. The same week, Nemr further clarified the limited scope of the grantees’ work by 

noting in two emails sent to all three companies that the monitoring should be focused on a specific 

set of Chinese and Russian state media sources. The first email, sent October 29, 2020, indicated 

that the Chinese “entities of interest” were “Global Times, Xinhua News, The People’s Daily, 

CCTV News, [and] Witianxia,” all Chinese state-sponsored media outlets. 

29. In a November 3, 2020, follow-up note, Nemr specified that the Russian outlets to 

monitor were the Strategic Culture Foundation, Inforus.ru, Infosco.org, Inforbrigs.org, and 

Oneworld.press. At our suggestion, we also added two other Russian state media sources, RT.com 

and Sputniknews.com, to the list we would monitor. 

30. Nemr’s November 3, 2020, email also specified the key questions for each of the 

companies: “What narratives is Russian govt/Russian backed media producing for US 

consumption?,” “Where is misinformation / disinformation produced for US consumption?” “Who 

is producing the content?” “Can the production and dissemination chain of information be mapped 

out?” Notably, those questions did not include anything about any activities undertaken by U.S. 

persons or news outlets. Rather, I understood all of these questions to relate to disinformation 

being produced, as the first question stated, by the Russian government and Russian-backed media. 

Subsequent discussions with the stakeholders from GEC and CNMF confirmed this understanding.

31. The project proceeded as follows: There were regular (approximately weekly) calls 

with representatives from the three companies and from GEC and CNMF. Ahead of the calls, each 

company would send a brief report about their findings from monitoring Russian and Chinese state 

media. The participants on the call would occasionally ask questions, the most common of which 

was whether we could identify whether state media had originated a particular false narrative or 

was just amplifying a narrative that already had appeared online.

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32. At no point, in my recollection, were any domestic media sources discussed in the 

context of mis- or disinformation, nor did any of our reports mention anything about the credibility 

or possible publication of misinformation by domestic media sources. We also received copies of 

the other companies’ weekly reports, none of which to my recollection focused on or mentioned 

anything about domestic news sources.

33. After the project was completed, NewsGuard had no relationship and little, if any, 

interaction with anyone from the Global Engagement Center or Park Advisors until about eleven 

months later in December of 2021, when we applied to a “call for submissions” from the GEC’s 

Technology Engagement Team to test capabilities related to content authentication technology.

The email from Nemr alerting us and others of the call for submissions made it clear that the project 

was focused exclusively on applications of technology to foreign disinformation, describing the 

mission as to “recognize, understand, expose, and counter foreign state and foreign non-state 

propaganda and disinformation efforts aimed at undermining or influencing the policies, security, 

or stability of the US, its allies, and partner nations.” In most cases, the term “content 

authentication technology” refers to technology that automatically detects whether images or video 

content are authentic or fabricated in some way. Though we do not offer content authentication 

technology ourselves, we submitted a proposal for testing whether our source ratings or 

Misinformation Fingerprints data, when combined with content authentication technologies that 

already exist in the market, could enhance results. Our proposal was accepted and we signed an 

agreement for $50,000 based on this premise, with the goal being for us to work with two contentauthentication technology providers to see how our data could enhance results. However, as we 

and our contact at the GEC explored how the project could proceed, we and they determined that 

a better course than the tests with the two technology providers would be to rescope the project to 

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focus on a single test of just NewsGuard’s capabilities. Thus, we never completed the work

described in that initial statement of work and instead agreed to look for alternative options for 

capability testing focused specifically on our Misinformation Fingerprints. Through that process, 

we were introduced to the State Department’s Venezuela Affairs Unit (“VAU”), which was 

interested in whether our data could help trace Russian state-sponsored false narratives spreading 

in Latin America through Venezuelan media outlets. After many discussions with the VAU we 

proceeded with this project, which we described publicly in a press release at the time. As the 

press release notes, this work involved NewsGuard monitoring “30 Venezuelan domains that 

regularly spread Kremlin-sponsored disinformation” and “25 additional news and information 

websites with high readership throughout Latin America – including Spanish publications owned 

and operated by authoritarian governments such as Russia and Iran and websites operating from 

other Latin American countries.” The project did not involve any rating or monitoring of U.S.-

based news outlets, including the plaintiffs’ websites, which to my knowledge do not cover 

Venezuela.

34. As with the 2020 project, during the Venezuela-focused project, we did not 

complete any ratings of news sources for this project, nor did we provide our ratings of news 

sources as part of the project. At no point during the VAU project were any U.S.-based media 

sources discussed in the context of mis- or disinformation. 

35. James Rubin, the head of the Global Engagement Center, was recently quoted in 

The Guardian as defining the GEC’s mission in this regard as follows: “We want to promote more 

fact-based information, but at the same time find ways to label those information operations that 

are generated by the Chinese government or the Kremlin but to which they don’t admit. In the end 

that is all I know we can do right now without interfering with a free press. We are not asking for 

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such covert disinformation to be taken down but a way to be found for the source to be labelled.” 

That is exactly the way in which NewsGuard attempted to assist the GEC—not to judge news 

sources or censor them, but to identify hostile-state interference with news dissemination.

The Independence of NewsGuard’s Ratings 

36. Plaintiffs’ claims are built on the false premise that the State Department and GEC 

are “actively intervening in the news-media market to render disfavored press outlets unprofitable 

by funding the infrastructure, development, and marketing and promotion of censorship 

technology and private censorship enterprises to covertly suppress speech of a segment of the 

American press.” ECF-1 ¶ 1. During the course of the project, however, nobody at Park Advisors, 

NSIN, GEC, the United States Cyber Command, CNMF, PeakMetrics, or Omelas aided, assisted, 

helped, or otherwise took any action to improve or develop NewsGuard’s website ratings. 

37. During NewsGuard’s work with GEC, no ratings of any news sources were 

commissioned, requested, funded, paid for, or otherwise completed as a part of a grant project. 

Nor was the concept of rating any news sources or providing NewsGuard’s ratings to GEC or 

CNMF part of the agreed Statement of Work for either project. Again, as set forth above, 

NewsGuard rated both The Daily Wire and The Federalist two years before it received the GEC

grant in 2020. Furthermore, at no point did GEC or CNMF in any way direct or instruct us to 

debunk any specific narrative, nor did they in any way instruct, inform, or direct our monitoring 

of news sources, beyond pointing us to the lists of foreign state-sponsored media sources to 

monitor. 

38. To highlight the absurdity of Plaintiffs’ allegations, during the period of the first 

grant project, The Daily Wire’s NewsGuard score actually increased by 7.5 points. In addition, 

from August 2021 to November 2023, which covers the entire period during which the Venezuela 

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project was completed, the site achieved a score of 69.5. Our rating scale describes any site with 

a score above 60 as credible, and many advertisers using our data choose to use a score of 60 as 

their threshold to advertise on a news site—though, as previously noted, that decision is up to each 

advertiser. Thus, because The Daily Wire achieved a score above 60 for most of the time following 

the start of our work with the GEC, it is likely that during that period The Daily Wire would have 

received more, not less, advertising revenue as a result of decisions advertisers made based on its 

NewsGuard score. 

39. The Federalist’s NewsGuard rating has stood at 12.5 points out of 100 since 2018, 

and The Daily Wire’s rating fell below the 60-point threshold in November of 2023, which the 

complaint implies is the result of the sites' content being considered “disfavored speech” by the 

U.S. government. This is false. Instead, the sites receive low scores because NewsGuard’s review 

of their content and transparency practices found that they do not meet NewsGuard’s standard for 

many of our nine criteria. For example, NewsGuard’s review of The Daily Wire’s content in 

January of 2024 found that “the website publishes podcast episodes on its site that have advanced 

misleading or inaccurate information,” and its most recent review of The Federalist found the site 

“has repeatedly published false information.” Nobody from the GEC, CNMF, or any other 

government agency was in any way involved in these determinations, and our Nutrition Labels for 

each site list numerous examples backing up our findings. While the plaintiffs claim that these 

supposedly government-directed determinations led to them losing advertising revenue, if they did 

indeed lose such revenue, it is due not to the government's actions but to their own. For example, 

there are many large advertisers that would find the recent podcast published on The Daily Wire 

website and podcast feed, in which The Daily Wire writers claim that former first lady Michelle 

Obama is secretly a man, to be content they would not want their brand associated with—and 

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within the free market of digital media, it is entirely within their rights to choose not to advertise 

on such content.

40. Another illustration of the absurdity of the plaintiffs’ claims is the fact that, while 

the complaint claims both NewsGuard and GDI were de facto government actors censoring views 

disfavored by the GEC, NewsGuard’s and GDI’s ratings differ significantly on their assessments 

of major news outlets. The complaint references a list published by GDI naming the ten “riskiest”

publishers in America, all of which were conservative news outlets. However, the complaint does 

not mention that NewsGuard’s ratings of these outlets were starkly different from GDI’s: Seven 

of the ten news outlets on GDI’s list were rated as credible by NewsGuard. Some, like the 

libertarian magazine Reason, have received perfect 100% reliability scores from NewsGuard. If 

the GEC were directing GDI and NewsGuard’s ratings as a covert means to censor certain views, 

one would expect that our two companies’ ratings would more closely align. In reality, we 

vigorously compete with GDI and have strong differences of opinion about the best way to rate 

news outlets fairly and accurately.

41. Finally, while the complaint refers to NewsGuard’s products as “censorship 

technology,” NewsGuard does not censor any content, nor is our primary product technology. 

Instead, we provide users and clients with information and journalistic reporting—in the form of 

apolitical ratings and reviews of news sources and analyses and debunks of false narratives—to 

equip them to make their own decisions about news they encounter online. Indeed, NewsGuard 

offers platforms, search engines, internet users, and others an alternative to blocking or censoring 

content that may contain misinformation. By providing transparent, detailed information that 

allows news consumers to assess the credibility of information sources for themselves, NewsGuard 

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