It also turned out that when you search for the plaintiff's name in English, you get a picture of the book in which a click on it yields the plaintiff's name (p. 13 of Revital Salomon's opinion). The expert on behalf of the defendant, Revital Salomon, also did not know how such a link was created (p. 67; paras. 28-30 in prot).
Thus, it turns out that the defendant created a link of the plaintiff to the book with his own hands. For the purpose of this link, the defendant did not need expertise in the field of computers or in search engine optimization. All the defendant is required to do is mention the plaintiff's name in connection with the book and to associate the plaintiff's name with the picture of the book. When it became clear, and there was no dispute among the experts, that typing the plaintiff's name in English linked the plaintiff to the book "The Bulgarian Fraud", there is no way to accept the claim that this is merely a coincidence. The more reasonable possibility is that the link was created because this is what the defendant wanted, and through uncomplicated actions in the form of mentioning the plaintiff's name in connection with the book.
- Second, it turned out that the picture distributed by the defendant was of an unknown person, whose first name was "Amit".
In one of the defendant's publications (published on August 20, 2015), the defendant writes about his interest in producing a film based on the book, and further writes that he was asked how he sees the character of the villain in the film that will be produced. The defendant presents a picture of a character that expresses how he sees the villain figure and notes that it is "a picture of someone I found on the Internet in a random search" (page 16 of the appendices to the plaintiff's affidavit). The picture (which has since been removed by the defendant and replaced with a cartoon figure) shows a balding, dark-skinned man, wearing glasses and wearing a mustache. This figure, as far as there is any doubt, does not mention the character of the plaintiff and there is no such claim. However, it turns out that a search for the same anonymous photo through the Google search engine connects the anonymous person in the photo to a person from India who answers to the name: Amit Arvind Agarwal (paragraph 8 of the plaintiff's affidavit).