On August 11, 2026, The Ethics Reporter received a letter from Thomas A. Clare of Clare Locke LLP — perhaps the most feared defamation firm in the United States — demanding that this publication retract and unpublish four articles about Citadel Securities and one of its executives. We reviewed the articles against the government's own enforcement record, made a handful of voluntary corrections, and declined. The next day, Mr. Clare wrote back asking us to itemize every change we had made, with dates and timestamps. The full text of that correspondence — his demand, our answer, and his reply — is published below, unedited.

We are telling you this because it is exactly how the machine is supposed to work — quietly. The letter arrives. The small publisher, staring down the prospect of litigating against a firm that extracted $787.5 million from Fox News, does the math on legal fees and deletes the story. No lawsuit is ever filed. No judge ever rules. The public record simply gets smaller, and nobody ever knows.

This is lawfare. And in 2026, it has become the preferred weapon of the wealthiest and most powerful people in America — not because they win these cases, but because they don't have to.

The Process Is the Punishment

Defamation law exists for a legitimate purpose: genuinely false statements of fact can destroy reputations, and the law provides a remedy. Nothing in this essay quarrels with that. The problem is what happens when litigation stops being a remedy and becomes a tax on speech itself.

Lawyers have a name for this category of suit: SLAPP — Strategic Lawsuit Against Public Participation. The defining feature of a SLAPP is that winning in court is optional. The plaintiff's real objective is achieved the moment the defendant has to hire counsel. Defending even a frivolous defamation claim through discovery can cost hundreds of thousands of dollars; defending a well-lawyered one can cost millions. For a hedge fund billionaire, a head of state, or a president, that money is a rounding error. For an independent journalist, a pollster, or a podcaster, it is existential.

A majority of states have enacted anti-SLAPP statutes, tracked state by state by the Reporters Committee for Freedom of the Press, that allow early dismissal of meritless speech suits and, in many cases, fee-shifting against the plaintiff. But there is no federal anti-SLAPP law, federal courts disagree about whether state anti-SLAPP statutes even apply in federal cases, and the remaining states offer thin protection or none. Delaware — the venue for the most closely watched defamation case in the country right now — has an anti-SLAPP statute, 10 Del. C. §§ 8136–8138, so narrow it largely covers only actions involving public applicants and permittees in land-use-style disputes. Plaintiffs know this. It is why they shop for the courts they shop for.

The Rise of the Elite Defamation Bar

No firm embodies the modern defamation-plaintiff industry like Clare Locke LLP, the Alexandria, Virginia boutique founded by Thomas Clare and Elizabeth Locke. The firm built its brand suing and threatening news organizations on behalf of the wealthy and the aggrieved, and it has real victories to its name — most famously representing Dominion Voting Systems in its case against Fox News, which settled in April 2023 for $787.5 million, the largest publicly known media settlement in American history.

Dominion was, in our view, a legitimate case: a company nearly destroyed by demonstrable falsehoods, litigated to the courthouse steps. But that victory did something else, too. It turned the defamation demand letter into a luxury product. A letter on Clare Locke stationery now arrives pre-loaded with the implicit message: we are the people who took three-quarters of a billion dollars from Fox News, and we are looking at you.

That is the letterhead that landed in this publication's inbox this month, on behalf of a market maker that handles a substantial share of all U.S. retail stock trades. Our series on Citadel Securities is built on the federal government's own enforcement record: the SEC's January 2017 settled order, under which Citadel Securities paid $22.6 million to settle charges of misleading conduct involving two undisclosed order-handling algorithms; the SEC's September 2023 order (Release No. 34-98482) finding that the firm mismarked millions of short-sale orders over a five-year period due to a coding error its own surveillance did not detect; and FINRA's October 2024 Letter of Acceptance, Waiver and Consent concerning years of late and inaccurate reporting of tens of billions of order events to the Consolidated Audit Trail. Fair and substantially accurate reporting on official government proceedings is privileged under New York Civil Rights Law § 74. Opinions drawn from disclosed facts are protected by the First Amendment. We said so, in writing, and we stand by the series.

Two details of this exchange deserve particular attention, because they capture the asymmetry of the whole enterprise. First: Mr. Clare's letter accuses this publication of denying his clients "a meaningful opportunity to comment" — and holds that failure up as evidence of actual malice. But The Ethics Reporter sought comment from Citadel Securities before the series ran and received nothing. Our response letter then formally re-extended the invitation through counsel, offered to publish any statement from his clients in full and unedited, and posed three specific on-the-record questions about accountability for the systems at issue. His reply answered none of them. The comment opportunity his letter demanded was sitting in front of him, in writing, and he let it sit. It still sits there today.

Second: when the retraction demand failed, Mr. Clare's follow-up did not identify a single statement in the revised articles that remains false. Instead, it instructed this publication to compile a dated, timestamped inventory of every edit we made — in effect, to assemble his case file for him, for free, without a lawsuit, without a subpoena, without any legal obligation whatsoever. That is not a correction request; corrections identify errors. It is discovery without the inconvenience of litigation, addressed to a publication he evidently assumed would be too frightened to notice the difference. An elite firm billing elite rates can read four articles and run a comparison on its own time. Our answer to that demand is this essay.

Whether Citadel Securities ever files anything is almost beside the point. The letter itself is the instrument. Multiply it by every small newsroom, every solo Substack writer, every academic who has ever received one, and you begin to see the shape of a censorship regime that never needs a censor.

The Macrons, Candace Owens, and a Courtroom in Delaware

Mr. Clare's most famous current clients are Emmanuel and Brigitte Macron — the sitting president of France and its first lady — who on July 23, 2025 filed a 22-count defamation and false-light complaint in Delaware Superior Court (Case No. N25C-07-194) against commentator Candace Owens over her "Becoming Brigitte" series and her repeated claims about Mrs. Macron's identity. The Macrons say the claims are false, fabricated, and spread for profit. Owens says she stands by her reporting and has fought the suit on jurisdictional grounds, disputing that Delaware is a proper venue. At a widely covered hearing in July 2026, the Macrons' lawyers pointed out that Owens herself had filed a defamation suit in Delaware in 2021. "We followed her lead," Mr. Clare told reporters. The case remains in active litigation, with motions to dismiss pending. In April 2026, longtime Trump lawyer Marc Kasowitz withdrew from Owens' defense team without stating a reason.

This publication takes no position on Owens' claims about the Macrons, and nothing here should be read as endorsing them. The Macrons, like anyone, are entitled to test their allegations in court. But step back and look at what the case is: two of the most powerful public figures on Earth — a head of state and his spouse, with the resources of considerable personal wealth and elite American counsel — litigating a foreign commentator's speech about them in a U.S. state court, in a state with one of the narrowest anti-SLAPP regimes in the country. Whatever a jury ultimately decides about the truth or falsity of Owens' statements, every independent commentator in America has now absorbed the lesson: say the wrong thing about the wrong person, and the most expensive lawyers alive will find a courthouse that suits them.

Owens is a genuinely polarizing figure, which is precisely what makes her a useful test case — for both sides. Speech protections that only get defended when the speaker is sympathetic are not protections at all. The First Amendment's actual-malice rule, announced in New York Times v. Sullivan, 376 U.S. 254 (1964), exists because public figures wield enormous power to command attention and shape their own narratives, and because a free society errs on the side of letting people criticize the powerful — even harshly, even wrongly at times — rather than letting the powerful decide what may be said about them. That principle is now under open assault, and not only in Delaware.

The President Who Sues

No one has done more to legitimize speech litigation as a tool of the powerful than Donald Trump — the most public figure in the world, and the most litigious president in American history. POLITICO maintains a running accounting of where his media lawsuits stand; the U.S. Press Freedom Tracker catalogs them as a press-freedom incident category of their own.

Consider the record. In December 2024, ABC News agreed to pay $15 million toward Trump's presidential library, plus $1 million in attorneys' fees, to settle a defamation suit over statements by anchor George Stephanopoulos. In July 2025, Paramount paid $16 million to end Trump's lawsuit over the editing of a 60 Minutes interview with Kamala Harris — a suit brought not even as defamation but under a consumer-protection theory that First Amendment scholars across the political spectrum described as baseless, settled while Paramount needed federal approval for its merger. Trump sued the Des Moines Register and veteran pollster J. Ann Selzer — for publishing a poll he didn't like — then dropped the federal case on June 30, 2025 and refiled it in Iowa state court the same day. As of early 2026, an Iowa judge had put discovery on hold while he weighs the Register's and Selzer's motions to throw the case out — which means a 40-year professional at the end of her career is still paying lawyers to defend a poll. Trump also sued the Wall Street Journal and Rupert Murdoch over its Epstein-letter reporting, demanding billions. Some of these cases may fail. That is not the metric. The pollster still had to lawyer up. The next pollster will think twice about publishing an outlier at all.

The settlements are the fuel. Every corporate parent that writes a check to make a weak case disappear — to protect a merger, a broadcast license, a stock price — publishes a price list. It tells every wealthy plaintiff in America that the media will pay to be left alone, and it tells every contingency-minded lawyer that the demand letter is a revenue instrument. ABC's settlement began an era. Paramount's confirmed it. The wave of suits and threat letters that followed, against outlets large and tiny, is the market responding rationally to demonstrated demand.

What It Costs — and Who Pays

The great newspapers will survive this era. They have insurers, in-house counsel, and shareholders. The people who will not survive it are the ones the First Amendment was most designed to protect: the small, the independent, the unbought. The local reporter covering a developer. The niche publication auditing a market maker. The podcaster, the pollster, the professor. For them, there is no legal department — there is only the letter, the fear, and the delete key.

We believe some things follow from all this, and we state them plainly as our opinion. Congress should pass a federal anti-SLAPP statute with mandatory fee-shifting, so that suing a critic into bankruptcy carries a price for the plaintiff too. States like Delaware should stop being venues of convenience for speech suits their own citizens would never tolerate. Courts should treat serial litigation and mass demand letters by the powerful as what they are — a First Amendment problem, not just a docket-management problem. And publishers, large and small, should do the one thing the lawfare model cannot survive: publish the letters. Sunlight is the only remedy that doesn't bill by the hour.

So we will go first.

The Correspondence, In Full

What follows is the complete text of the exchange between Clare Locke LLP and The Ethics Reporter, reproduced verbatim: Mr. Clare's August 11, 2026 cease-and-desist demand, this publication's response later that day, and Mr. Clare's August 12 reply. We have added nothing and removed nothing beyond formatting the demand letter, which arrived as a single unbroken block of text, into paragraphs for readability.

I. The Demand — Thomas A. Clare to The Ethics Reporter, August 11, 2026

To Whom It May Concern:

I am defamation counsel for Citadel Securities and Kevin Nutter. I write to demand that The Ethics Reporter (1) immediately cease and desist from making false, misleading, and defamatory claims about my clients, (2) fully retract four articles published that contain false, misleading, and defamatory claims regarding my clients, and (3) retract any other similar statements about my clients.

On at least four occasions, The Ethics Reporter has published false and defamatory claims about my clients. Specifically, the following four articles materially misrepresent Mr. Nutter's work and contain serious, false allegations about Citadel's processes and information barriers: i. The Machine Behind the Market: How Citadel Securities, Kevin Nutter, and $100 Million in Political Money Built an Accountability-Free Empire, published on May 15, 2026; ii. Part 3: Regulatory Failures – Why Citadel's Fines are Negligible and Kevin Nutter's Systems Keep Enabling Violations, published on May 14, 2026; iii. Part 4: The C-Suite at Citadel – Profiles of Power, Strategy, and Kevin Nutter's Critical Role, published on May 14, 2026; iv. Part 5: What Should Happen – Five Regulatory Solutions and Why None Have Been Implemented, published on May 14, 2026.

These articles falsely assert that my clients have designed and implemented and continue to maintain surveillance systems and data architecture for the purpose of defrauding customers and concealing billions of dollars from federal regulators. The articles compound these accusations by alleging that my clients intentionally ignore and intentionally elect not to fix systemic failures. Further, the articles accuse my clients of political corruption by purportedly establishing a link between my clients' alleged political contributions and the conduct and decisions of political officials in matters of trade regulation. There is no truth to these claims. And we reject, in the strongest possible terms, any allegations of fraud, mismanagement, or bribery.

As one example, in the May 15, 2026 article, The Machine Behind the Market: How Citadel Securities, Kevin Nutter, and $100 Million in Political Money Built an Accountability-Free Empire, The Ethics Reporter published the following claim: [Citadel Securities] has operated with near-total impunity. This is not an accident. It is the result of a deliberate strategy – one that involves secret algorithms designed to give customers worse prices, four years of concealing tens of billions of transactions from federal regulators, a multibillion-dollar bailout of a failing hedge fund on the eve of the GameStop collapse, and $100 million in political spending that culminated in the death of the one market reform that could have broken Citadel's grip on the retail order flow.

The Ethics Reporter then tied Mr. Nutter to the allegations of fraud, stating: [Kevin Nutter's] role makes him a central figure worth scrutinizing in connection with what may be Citadel's most significant and least discussed regulatory failure: four consecutive years of failing to report tens of billions of transactions to federal regulators.

These assertions are, without exception, false. And because these allegations charge serious crimes (such as fraud) and attack my clients in their business affairs, they are defamatory per se. Kasavana v. Vela, 172 A.D.3d 1042, 1044 (N.Y. App. Div. 2019); Klayman v. Jud. Watch, Inc., 22 F. Supp. 3d 1240, 1247 (S.D. Fla. 2014), aff'd (Feb. 17, 2015).

The article offers no evidentiary support for any of these allegations because it cannot. Apparently undeterred by the lack of evidence, the article selectively draws on two discrete regulatory fines previously imposed by the Securities and Exchange Commission ("SEC") and the Financial Industry Regulatory Authority ("FINRA"), in order to extrapolate an ongoing pattern of abuse and illegal activity. That is a logical inference belied by the underlying record. In making this leap, the article openly assumes, without any basis, that my clients neither cooperate with regulators nor treat remediation as a substantive obligation, baselessly characterizing my clients' view of regulatory fines as "a business expense." Those assumptions are directly contradicted by facts the article itself acknowledges: my clients "completed remediation of the reporting failures" flagged by FINRA and timely "submitted corrections."

Lodging defamatory allegations while relying exclusively on "rumors" or baseless "reports" is evidence of actual malice. See, e.g., Hale v. Scott, 371 F.3d 917, 919 (7th Cir. 2004) (Posner, J.) ("As there is no indication that Hale had any basis for believing the rumor . . . to be truthful, he was guilty of 'actual malice.'"); Martin v. Wilson Publ'g Co., 497 A.2d 322, 330 (R.I. 1985) (Publication of "false or baseless rumors . . . makes the publisher responsible under the 'actual malice' test of New York Times for ascertaining the truth of the underlying defamatory material."). And publishing a story that is internally inconsistent or that ignores contradictory evidence is also a sign of actual malice. Celle v. Filipino Rep. Enters. Inc., 209 F.3d 163, 186 (2d Cir. 2000); Goldwater v. Ginzburg, 414 F.2d 324, 337 (2d Cir. 1969) (ignoring contradictory evidence in pursuit of a preconceived storyline constitutes evidence of actual malice); Eramo v. Rolling Stone, LLC, 209 F. Supp. 3d 862, 873 (W.D. Va. 2016).

The few facts the article does provide it distorts, for example by manipulating timelines to paint a picture of ongoing corruption. The article reports events in reverse order. It begins with the FINRA and the SEC fines, which occurred in October 2024 and September 2023 respectively. It then arrives at a contrived crescendo: the bailout of Melvin Capital Management which occurred in January 2021. The article treats this inversion of events as if it were the true timeline and recasts the Melvin bailout as a "visible collision" of alleged "algorithm fraud" and "short-sale mismarking." In doing so, the article baselessly spreads the falsity that the two fines in 2023 and 2024 were evidence of some nefarious, escalating scheme rather than discrete events separated by time and context. This framing, which groundlessly collapses distinct occurrences into a single fantastical arc, is not only extremely misleading to The Ethics Reporter's readership, who deserve better from their journalists. It is also a distortion of events that is further evidence of actual malice.

The other articles identified advance similar false claims about my clients and similarly lack evidence to support their inflammatory assertions. While the articles contain brief, passing references characterizing the allegations as editorial opinion, such disclaimers are insufficient to "defuse the impression" that the articles are communicating statements of fact. Future Ads LLC v. Gillman, No. SACV 13-cv-905-DOC, 2013 WL 12306479, at *6 (C.D. Cal. Dec. 23, 2013) ("Qualifying the [defamatory] statement with the word 'potential' does not help; couching an assertion of defamatory fact in cautionary language does not defuse the impression that the speaker is communicating an actual fact."); Croce v. N.Y. Times Co., 930 F.3d 787, 795-96 (6th Cir. 2019) ("Of course, even with qualifying language, a defendant could be liable for publishing statements with actual malice."). A perfunctory disclaimer, particularly one buried in or appended to otherwise declarative, accusatory prose, does not neutralize the factual impression that the surrounding content creates in the mind of the reader. This is especially true when the articles conclude with a call to action demanding true "accountability" and that Mr. Nutter be held personally liable for the alleged misconduct.

Not only do these articles expose The Ethics Reporter to legal liability for defamation, but they are also a violation of The Ethics Reporter journalists' ethical responsibilities. Journalists have a professional, ethical responsibility to treat story subjects with "scrupulous fairness," (E.g., NPR, Ethics Handbook: Fairness, https://www.npr.org/about-npr/688177789/fairness.) should afford subjects a meaningful opportunity to "point out holes or contradictions," and should not avoid "hear[ing] challenging, detailed rebuttals" to contemplated publications. E.g., Sheila Coronel et al., Rolling Stone's investigation: 'A failure that was avoidable,' Colum. Journalism Rev. (Apr. 5, 2015), https://www.cjr.org/investigation/rolling_stone_investigation.php. The Ethics Reporter's own policies state that the publication maintains "a focus on accuracy and fairness" and claims that "ethical conduct is not just a professional obligation but a cornerstone of justice itself." But The Ethics Reporter failed on every front here. It did not give my clients a meaningful opportunity to comment before publishing its highly inflammatory pieces, as journalistic standards require. Such a comprehensive failure constitutes strong circumstantial evidence of actual malice.

Now that The Ethics Reporter is on notice of its errors and the falsity of its publications, it must take down the identified defamatory articles. Failure to do so would be further evidence of actual malice. I further demand that, moving forward, The Ethics Reporter provide my clients a meaningful opportunity to respond before publishing any article reporting on them or their work.

I trust that The Ethics Reporter will treat the issues raised in this letter with the seriousness and diligence that it owes to its readers and my clients. This is not a full statement of my clients' rights and remedies, all of which are expressly reserved.

Very truly yours,
Thomas A. Clare, P.C.

II. The Response — The Ethics Reporter to Thomas A. Clare, August 11, 2026

Dear Mr. Clare:

We write in response to your letter demanding that it cease and desist from, retract, and unpublish four articles concerning Citadel Securities and Kevin Nutter. The Ethics Reporter takes seriously both its obligations under the law of defamation and its own standards of accuracy and fairness. For that reason, upon receipt of your letter, the publication undertook a comprehensive review of all four articles against the primary sources on which they rest — including the Securities and Exchange Commission's January 13, 2017 order and accompanying release, the Commission's September 22, 2023 administrative order (Release No. 34-98482), and FINRA's October 2024 Letter of Acceptance, Waiver and Consent — as well as the governing law.

1. The articles have been reviewed and, where warranted, revised.

Consistent with its editorial standards, The Ethics Reporter has revised the articles and published a dated corrections note. Among other things, the publication corrected a numerical characterization of FINRA's findings (42.2 billion order events — a count of reporting events, not a dollar figure), corrected two collateral dates and names, revised certain passages so that the editors' opinions and questions are expressly stated as such and expressly tethered to the disclosed public record, and appended to each article a standing editorial note confirming that the series draws on settled regulatory findings that Citadel Securities neither admitted nor denied, and that the publication claims no knowledge of any individual's state of mind. These revisions were made voluntarily, in the ordinary course of the publication's commitment to accuracy. They are not, and should not be construed as, an admission that any prior statement was false, defamatory, or actionable.

2. The demand for retraction and takedown is declined.

The factual core of this series is the federal government's own record. The SEC found — in a settled order your letter nowhere disputes — that two undisclosed Citadel algorithms either "immediately internalized an order at a price that was not the best price" or routed orders "not priced to obtain immediately the best price," resulting in a $22.6 million payment. The SEC further found that for five years Citadel Securities mismarked millions of short-sale orders, and that the firm's own surveillance tools "did not detect either the coding error or the firm's mismarking." FINRA found that for more than four years Citadel Securities failed to timely and accurately report tens of billions of order events to the Consolidated Audit Trail. Fair and substantially accurate accounts of those official proceedings are absolutely privileged, N.Y. Civil Rights Law § 74; Holy Spirit Ass'n v. New York Times Co., 49 N.Y.2d 63 (1979), and true statements are not actionable at all. The series' broader arguments — that the resulting fines are disproportionately small, that the dual hedge-fund/market-maker structure embodies a conflict of interest, and that regulators should audit what they have never audited — are constitutionally protected expressions of opinion on fully disclosed facts. Steinhilber v. Alphonse, 68 N.Y.2d 283 (1986); Gross v. New York Times Co., 82 N.Y.2d 146 (1993); Immuno AG v. Moor-Jankowski, 77 N.Y.2d 235 (1991); Mann v. Abel, 10 N.Y.3d 271 (2008); Milkovich v. Lorain Journal Co., 497 U.S. 1 (1990).

Your letter's assertion that the articles "offer no evidentiary support" for their claims is difficult to reconcile with the articles themselves, which cite — and now hyperlink — the Commission's and FINRA's orders, the January 25, 2021 Melvin Capital announcement, Citadel's own March 2023 comment letter opposing the Order Competition Rule, the Commission's June 2025 withdrawal notice, and Federal Election Commission data as reported by OpenSecrets. Nor is the "manipulated timeline" charge accurate: the flagship article proceeds chronologically from the 2007–2010 algorithm conduct through the 2017 settlement, the 2015–2020 marking violations, the 2020–2024 CAT reporting failures, the January 2021 events, and the 2024–2025 political spending and rule withdrawal. And as to fairness: the GameStop discussion expressly reports the clearinghouse explanation for the trading restrictions, your client's denial of coordination, the findings of the congressional and SEC staff reports, and the dismissal of the coordination lawsuits. The publication stands behind the revised articles in their entirety.

3. Regarding Mr. Nutter.

The series reports Mr. Nutter's title and background as reflected in professional directories, observes — accurately — that no individual has ever been publicly identified as accountable for the data systems whose failures produced the enforcement actions described above, and argues, as opinion, that executives holding critical infrastructure roles at firms with documented regulatory failures should be publicly identifiable and publicly answerable. Naming an executive and asking who is accountable is lawful journalism on a matter of profound public concern. If your clients contend that any specific factual statement about Mr. Nutter's role remains inaccurate following the revisions, identify the statement and the respect in which it is claimed to be false, and the publication will promptly evaluate it, as it would any correction request.

4. Request for comment and standing invitation to respond.

Your letter faults The Ethics Reporter for an asserted failure to afford your clients a meaningful opportunity to respond. The publication sought comment from Citadel Securities before publication and received none. In any event, the opportunity your letter demands is hereby extended formally, and — because your clients are represented by counsel in this matter — it is extended through you:

(a) The Ethics Reporter will publish, in full and unedited, any responsive statement from Citadel Securities, Citadel LLC, or Mr. Nutter concerning the matters addressed in this series;

(b) The publication specifically invites your clients' on-the-record answers to the questions at the center of the series: How is responsibility for regulatory reporting infrastructure allocated between Citadel LLC's data organization and Citadel Securities? What is Mr. Nutter's actual mandate as Chief Operating Officer of Data? And has any regulator ever audited, at the system level, the information barriers between the hedge fund and the market maker?

(c) Going forward, The Ethics Reporter will direct pre-publication requests for comment concerning your clients to your attention, unless you advise that such requests should be directed elsewhere. Please confirm that you will accept them.

A refusal to engage on the merits, coupled with a renewed demand that truthful, privileged, and opinion-based reporting simply be erased, will speak for itself.

We trust that your clients will treat the questions posed in Section 4 with the seriousness they owe to the investing public.

— The Ethics Reporter Editorial Board

III. The Reply — Thomas A. Clare to The Ethics Reporter, August 12, 2026

To Whom It May Concern:

I have received your correspondence rejecting our takedown request. I am evaluating your response and will respond more fully after our review is completed.

In the meantime, please identify specifically the modifications made to the articles at issue — including the nature of each change, and the date and time each change was implemented.

Tom Clare

Thomas A. Clare, P.C.
Clare Locke LLP

That is where the matter stands as of this writing. The Ethics Reporter received a demand from the most successful defamation firm in America to erase reporting built on the federal government's own findings. We reviewed our work, corrected what warranted correction, declined the rest, and invited Citadel Securities to respond on the record — an invitation extended before publication, renewed in writing through counsel, and unanswered to this day. What came back instead was a demand that we document our own edits for the firm's convenience. We respectfully suggest that a firm of Clare Locke's reputation is capable of doing its own homework. We are not publishing this correspondence because we are brave. We are publishing it because the entire model depends on targets staying quiet, and we decline that request as well.

The Ethics Reporter is a reader-supported publication. We have no advertisers, no corporate sponsors, and — as this essay should make clear — no shortage of powerful critics. If independent accountability journalism matters to you, you can support our work at theethicsreporter.com/donate.

Sources

• SEC, "Citadel Securities Paying $22.6 Million to Settle Charges of Misleading Conduct" (Jan. 13, 2017), and accompanying settled administrative order
• SEC, press release on Citadel Securities' Reg SHO short-sale marking violations (Sept. 22, 2023) and Administrative Order, Release No. 34-98482
• FINRA, Disciplinary Actions database (October 2024 Letter of Acceptance, Waiver and Consent re: Consolidated Audit Trail reporting)
• NPR, "Fox News settles blockbuster defamation lawsuit with Dominion Voting Systems" (Apr. 18, 2023)
• Macron v. Owens, Del. Super. Ct. No. N25C-07-194 (filed July 23, 2025): Complaint and public docket
• Delaware Online, "Can Emmanuel and Brigitte Macron sue Candace Owens in Delaware?" (July 28, 2026)
• Bloomberg Law, "Trump Lawyer Kasowitz Leaves Candace Owens Team in Macron Case" (Apr. 2026)
• POLITICO, "Trump is still going after the press in court. Here's where his lawsuits stand." (Mar. 4, 2026)
• U.S. Press Freedom Tracker, "Media in the courthouse" (litigation tracker)
• The Hill, "Media shifts to more aggressively fight Trump in courts" (Aug. 2026)
• CBS News, "Trump sues Des Moines Register over poll, promises more lawsuits against news outlets after ABC News settlement" (Dec. 17, 2024)
• New York Times Co. v. Sullivan, 376 U.S. 254 (1964)
• Reporters Committee for Freedom of the Press, Anti-SLAPP Laws (state-by-state guide)
• Delaware Code, 10 Del. C. ch. 81 (§§ 8136–8138)
• Correspondence between Clare Locke LLP and The Ethics Reporter, Aug. 11–12, 2026 (reproduced in full above)

Editorial note and disclosure: Clare Locke LLP, on behalf of Citadel Securities and an executive, has demanded the retraction of four Ethics Reporter articles referenced in this essay. The Ethics Reporter has declined that demand and stands by the revised articles. Descriptions of pending litigation in this essay — including Macron v. Owens (Del. Super. Ct., filed July 23, 2025) and lawsuits filed by President Trump — are based on public court records and contemporaneous news reporting; allegations in pending cases are just that, allegations, and each defendant is presumed to dispute them. The correspondence above is reproduced from the parties' own letters; the assertions within each letter are those of its author. This essay expresses the editorial opinion of The Ethics Reporter on matters of public concern, grounded in the disclosed public record.