The protracted legal confrontation between Hunter Biden and former Overstock CEO Patrick Byrne is edging towards a pivotal hearing slated for early next year, though it may not conclude the entire saga. A recent document submitted in court seeks to shed light on certain aspects for the judge presiding over the case.

Last Friday, Biden filed a four-page supplement to his default motion, in which he accused Byrne of continuing to defame him.

In this filing, Biden aims to “inform the Court of recent public statements” that Byrne allegedly made, which he claims repeat “the same Defamatory Statements on a widely distributed public forum” that constitute the core of the lawsuit.

The supplement argues that Byrne’s ongoing public dissemination of these defamatory statements is indicative of potential future defamation unless significant punitive damages are imposed, as previously requested in Biden’s Default Judgment Motion. It highlights that the Court’s previous order, which denied Byrne’s summary judgment, found no basis for the defamatory claims.

The statements in question were reportedly made by Byrne during two December appearances on “The Alex Jones Show” and “War Room LIVE,” both hosted by right-wing conspiracy theorist Alex Jones.

The supplement also reviews the promotional content for these online broadcasts, underscoring the reach and influence of the platforms on which Byrne allegedly repeated the defamatory statements.

From the filing, at length:

[A]n X account attributed to Alex Jones posted the full 14-minute clip of Defendant’s interview with the caption: “Breaking Exclusive! Hunter Biden Solicited An 800 Million Dollar Bribe From Iran In Exchange For His Father Joe Biden To Unfreeze 8 Billion Dollars In Frozen Iranian Assets, CIA Whistleblower Patrick Byrne Tells Alex Jones In This Bombshell Report. To Bolster His Claim, Byrne Has Released One Of Many Exclusive Audio Tapes In His Possession.

Biden says the X, formerly Twitter, post by Jones including the full clip has been viewed over 121,000 times as of the date of the filing.

“In the full clip posted by Alex Jones on December 9, 2025, not only does Defendant reiterate the same Defamatory Statements at issue in this matter, but he doubles-down on them by taunting Plaintiff about this lawsuit and publicly states he harbors malice toward Plaintiff,” the supplement reads.

In the underlying lawsuit, Biden claims Byrne defamed him during a June 2023 interview — and then again in October 2023.

Biden says Byrne made false claims that he and his family solicited bribes from the Islamic Republic of Iran in exchange for the Joe Biden administration releasing billions of frozen Iranian funds and for adopting a pro-Iranian position during “nuclear talks.”

Trial in the case has been serially delayed.

After originally being slated for December 2024, the trial was pushed back to this past summer – on a motion to continue filed by Byrne. Then, in July, the trial was pushed back to October – after a false start where Byrne suddenly fired his lawyers and failed to convince the judge to grant another attorney pro hac vice permission to represent him instead.

Then, the jury trial was once again pushed back — this time to January 2026. Around the same time, the court entered a default against Byrne, essentially a formality required before Biden can be awarded a default judgment.

Now, Biden says Byrne is even talking about the litigation delays in a way that makes him, the plaintiff, look responsible.

“Defendant even claims Plaintiff is scared to face him in Court about these allegations despite Plaintiff being ready to proceed to trial last July with Plaintiff present every day in the courtroom while Defendant’s misconduct in delaying the trial, failure to appear for trial, and then intentionally ignoring this Court’s orders led to default being entered against him as a sanction,” the supplement goes on.

Biden goes on to allege that Byrne violated a protective order in the case by playing a voicemail on one of the broadcasts.

“Defendant has intentionally violated the Stipulated Protective Order,” the supplement continues. “Defendant has again shown he has no intention of obeying the orders of this Court.”

To hear Biden tell it, Byrne must be punished due to such alleged repeat violations of the court’s orders and decorum.

“This republication of the defamatory statements along with a HIGHLY CONFIDENTIAL recording years after the defamatory statements were first published and during the pendency of this matter demonstrates Defendant is a recidivist who will continue to maliciously attack Plaintiff with false statements,” the supplement goes on. “Nothing short of a harsh punitive damages award will be effective in curbing Defendant’s ongoing defamatory conduct against Plaintiff and outright disregard for this Court’s orders.”

And, in a footnote, Biden likens Byrne’s alleged behavior to that of President Donald Trump with regard to his repeat defamation of journalist E. Jean Carroll – violations that have resulted in tens of millions of dollars in liability in New York state courts.

Again, the filing, at length:

Considering that Defendant has continued to defame Plaintiff with the same false statements at issue in this case, this case is comparable to E. Jean Carroll’s case against President Donald Trump. In the first case, Ms. Carroll was awarded $5 million for defamation resulting from President Trump stating she lied about being sexually assaulted by him. Following that judgment, President Trump made the same defamatory statement for which he was previously found liable, and, at a second trial, Ms. Carroll was awarded additional damages, including $65 million in punitive damages alone, a 13x increase in damages from the first trial.