Ryan Reynolds’ reply in support of his motion to dismiss in Blake Lively v. Wayfarer Studios LLC et al. (S.D.N.Y. No. 24-cv-10049) is a methodical dismantling of the Wayfarer Parties’ claims against him. Ryan Reynolds just filed his reply in support of his motion to dismiss the $400 million lawsuit brought by Justin Baldoni and his Wayfarer co-plaintiffs—and he’s not holding back.

In his final word before the judge rules, Reynolds argues that the case is legally defective across the board. His team dismantles the claims one by one, beginning with defamation: there are only two actual statements identified (“the predator comments”), and they concern Baldoni alone—not the other six plaintiffs who inexplicably sued him. Beyond that? No names, no dates, no quotes. His lawyers describe it as suing someone for a “ghost story.” They argue the comments are opinion, not fact—and even if considered factual, they’re “substantially true” based on Baldoni’s own public statements. Reynolds also says there’s no actual malice, no false light (New York doesn’t even recognize that tort), and—critically—no damages. Not even a token dollar.

The civil extortion and tortious interference claims? Dead on arrival. No demand for money, no loss of property, no proximate cause, no actual disruption—and no contracts even identified. Reynolds also seeks attorney’s fees under New York’s anti-SLAPP statute, asserting this lawsuit was brought to punish him for speech. His message is clear: suing a co-star because your feelings were hurt isn’t a valid legal theory.

Here’s a detailed analysis of the strongest and weakest points of his reply:

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STRONGEST ARGUMENTS

1. Damages and Proximate Cause (pp. 7–8, 10)

• Reynolds convincingly argues that the Wayfarer Parties failed to allege any pecuniary damages or establish a causal link between his conduct and their alleged harms.
• Notably, their opposition brief does not even mention “proximate cause” and concedes that damages were presumed under defamation per se without showing any actual harm.
• This is devastating to their tortious interference and civil extortion claims, both of which require concrete damages.

2. Lack of Specific Statements (pp. 3–4)

• The reply points out that the First Amended Complaint (FAC) only identifies two statements (“predator statements”) allegedly made by Reynolds and fails to provide any detail such as time, place, or recipient.
• The reliance on “Exhibit A,” which is not part of the FAC, is effectively challenged as improper under Rule 12(b)(6) standards.

3. The Defamation Claim Targets Only Baldoni (pp. 4–5)

• Reynolds isolates the scope of the alleged defamation to Baldoni, noting that six of the seven Wayfarer Parties have no connection to the allegedly defamatory statements.
• This paves the way for dismissal of those parties’ claims as they are not “of and concerning” them.

4. Substantial Truth and Opinion Defense (pp. 5–6)

• Reynolds argues that the “predator” label is non-actionable opinion, particularly in light of public statements Baldoni himself made.
• The team highlights that even if the term is inflammatory, the meaning is not materially different from the “truth” that the Wayfarer Parties themselves disclosed—i.e., the impact on the listener would be the same.

5. Conspiracy Theory Failure (pp. 13)

• The reply destroys the FAC’s conspiracy allegations by pointing out they are all made “on information and belief,” unsupported by any specifics, and fail to allege unlawful joint action.
• WEAKNESSES OR VULNERABLE POINTS
• 
  Overreliance on Judicial Notice (p. 5)
  The reply argues that the court should take judicial notice of public statements made by Baldoni to justify a “substantial truth” finding at the pleading stage. Courts are sometimes cautious with such requests in 12(b)(6) contexts, especially if the truth of those materials is disputed.
  
• Push for Attorney’s Fees (pp. 13–15)
  The request for attorney’s fees under New York’s anti-SLAPP statute is legally plausible but invites debate. Although the reply relies on Bobulinski and other recent S.D.N.Y. cases that have allowed such recovery post-Adelson, the Second Circuit has not definitively resolved the federal application of N.Y. Civ. Rights Law § 70-a. This issue may prompt judicial hesitation, particularly absent a motion brought post-dismissal.
  
• Slight Overreach in Group Dismissal Argument (pp. 1–2)
  Reynolds asserts that every party except Baldoni lacked a legal basis to sue, potentially exposing him to Rule 11 sanctions. While compelling, courts may hesitate to dismiss claims solely on this basis without deeper scrutiny of each individual plaintiff’s standing and claims.
  
  STRATEGIC RECOMMENDATIONS
  Reinforce Lack of Proximate Cause and Damages Across Claims: Emphasize the plaintiffs’ silence on damages and causation in subsequent briefs. Courts take seriously omissions on core elements.
  Separate Dismissal for Each Wayfarer Party: Request the court explicitly address dismissal of claims by individual parties like IEWUM, TAG, Nathan, Abel, and Sarowitz, who were not allegedly defamed or affected by Reynolds’ conduct.
  Reassert Improper Use of Exhibit A: Move to strike or emphasize the irrelevance of Exhibit A again if the court appears to weigh it.
  Push Substantial Truth and Opinion Together: Argue that the “predator” comment not only reflects opinion but mirrors Baldoni’s own public admissions, reducing First Amendment risk for Reynolds.
  Anticipate Anti-SLAPP Debate: Be prepared with both procedural and policy-based justifications for awarding fees under § 70-a, including policy statements from the New York legislature and comparable circuits that have approved similar provisions.