im not going to address the 402 points you are making...but ill take the first few...
"“Fake factories,”"
changing from one factory to another and then another without ever producing anything leaves room for the accusation...like it or not...
"“nonexistent product,”"
definition of "product"......"an article or substance that is manufactured or refined for sale.".....15 years since the breakthrough and there have been no sales...research or samples is not product for sale...thus "nonexistent product" is not totally inaccurate....like it or not...
" “fabricated production numbers”"
kim has repeatedly put out production numbers that have never occurred...tonnage by this date or end of year etc...he has claimed the start of commercialization many times without it having occurred...kim promised to put out wip numbers that should have been in the last 10q...they werent....the accusation of fabricated numbers is not altogether unjustified...like it or not...
" “Nonexistent product” is not an opinion."
no...it is actually a fact...lol
"Facilities exist, operated, were relocated, and have been inspected, documented, and disclosed in filings."
the existence of a factory does not preclude the claim of it being fake....after so many years and so many changes, the mere fact that various factory buildings have existed without ever producing product makes the claim of "fake" not really that outlandish...and also not actionable under those circumstances...
i could go on but ive got things to do...the fact of the matter is, there is no case for libel or defamation...just because you dont like it and dont approve doesnt mean its illegal...