What you’ve said and what I’ve said are not in conflict. Coinbase clearly states that they believe there to be three complaints and that they’re generally in the clear.

My point about reading between the lines is that the explicit, specific repetition of the claim and the way they’re saying it implies that the NYT is going to allege there were more complaints.

So then: what of the missing complaints? What Coinbase is saying, essentially, is that whatever else is alleged either didn’t happen (eg, the NYT is outright lying), or that they weren’t really complaints.

That’s what I’m getting at. It’s highly unlikely that the NYT is lying. I would be shocked if they did not verify in some way that the complaints alleged were indeed made to Coinbase. And I also do not think that Coinbase would accuse the NYT of lying either. It’s not a particularly defensible position.

So - that’s the reading between the lines. To me, the most plausible explanation is that the NYT will allege multiple complaints, and Coinbase is trying to say “no those don’t count.”