The filing contends that the plaintiffs should be held financially accountable for the mounting costs caused by the delay. Paramount claims the merger is ready to close, with regulatory approval secured across 69 jurisdictions. According to the company, the standstill order is triggering significant financial damage, which they estimate could reach $1.88 billion if the litigation continues to block the transaction.

While Paramount stated it is not seeking to lift the court's current no-close order, it maintains that the Clayton Act and Rule 65 provide a mechanism for protection against losses incurred during such injunctions. The company emphasized that its agreement to delay the closing was intended to facilitate a prompt trial, not to waive its right to financial security. Paramount asserts that the lawsuits are meritless, pointing out that the plaintiffs have not disputed the company’s calculations regarding the quantifiable harm caused by the postponement.