Without reading the Complaint, I am asuming from a review of Coughlin's motion to dismiss, that Mr. Renner's request for declaratory judgment is similar to CraigList suing the South Carolina AG - where Craig's List sought and obtained  a federal restraining order against the AG.

Because threats to sue - before publication - for defamation  have the clear intent to chill freedom of the press, I don't agree with Cougnlin that there is no dispute or issue.   The active issue is did Coughlin attempt to use the theat of a groundless lawsuit to chill Renner's right to freedom of press/speach?