"Shown" as reckless is not something that happens in a vacuum. If he was reciting the terms of a contract in the pr (the buildout in 30 cities, etc.) agreed to by the Russian partners, many jurors would not conclude that such statements rise to the level of "reckless", especially if safe harbor statements were included, warning that the Russian partners could default, etc. If he had a reasonable basis (past experience, current and future projected growth of internet and telecom services in Russia, cost to construct and maintain the Hotzone system, etc.), again, a jury would not necessarily find his projections "reckless". Another poster made a huge point which many seem to miss here: you can't prove your case without the Russians and the plaintiffs will have to pay for the Russians to be deposed, the Russians will have to cooperate, and a jury ultimately has to find them more believable than Huff.