In the case of Buzzfeed, Cohen not only had to prove that he’d never been to Prague but that Buzzfeed KNEW HE HAD NEVER BEEN TO PRAGUE and acted maliciously in publishing the falsehood. The bar for actual malice is so high that he probably couldn’t win anyway. Now, Fusion GPS, which compiled the dossier? Yeah, I don’t see why Cohen would let them off the hook unless he didn’t want to be deposed and have to talk about whether or not he’d been to Prague. That’s REALLY problematic.
Fusion GPS is going down anyways. Once Michael is clear of this Witch Hunt, he can refile against Fusion and BuzzFeed, both will be crawling over glass to settle with him.