The first rule in a civil law suit is: Show me the provable damages. Cases of slander (spoken) or libel (written or printed) are damn near impossible to prosecute and win.

The Plaintiff must prove::
1. You made the untruthful utterance or writing that caused him actual monetary damage. Just being insulted or pissed off isn't enough. This damage must be proven by sworn testimony, not simply by unsupported documents. However, by complaining of monetary losses, he opens the door to disclosing his full accounting and banking records that would otherwise be protected because they directly relate to his tax obligations.
2. You knew, or should have known, that your action was harmful to the reputation of the complainant. Actual intent is not at issue.
3. You knew that your statements were false and unsupported by factual first hand knowledge.

Here comes the fun part. Bigbabo is in SoCal down near San Diego? He could file a case and serve it in California against a California resident but the proper venue would be in the defendant’s jurisdiction. This means he must travel and have his attorney travel or hire local council in the defendant’s local court system. A retainer will cost him $5,000 minimum.

As a defendant, you would first demur and make them clarify their suit with specific pleadings. Then, if they got that right, you would answer by cross-complaining and cite his suit as frivolous. This lays the groundwork for you to recover your expenditures caused by his law suit. Then you would lay a mountain of paperwork on him such as Admissions, form interrogatories, special interrogatories, production of documents, witness lists, and then deposition. That should add $10,000 to his attorney’s bill. Most attorneys charge $5,000 a day for actual court trail and three days is a minimum.

If you are in California and 150 miles away from him, he must come to you for deposition. But he must also come to you to be deposed. That gets expensive for him too.

If you live outside of California. Just ignore his California Complaint. Sister States do not honor default judgments where actual or intrinsic fraud is not at issue..

If you really want to stick a brick in his ass. Failure to complete an online auction, or misrepresentation of an auction product is a violation of California Penal Code section 535. Many big city sheriff’s departments have “high tech” crime units with nothing better to do than pursue allegations of online frauds.