I think the subpoena is mostly for existing records and novel records of existing plans. IANAL, but I think if you were to create novel documents that were most certainly less than honest for the purpose of swaying the case, there could be legal consequences for you.
Courts aren't stupid - if it becomes apparent that you are attempting to maliciously comply, they can still get you based on your apparent intent.
Simula has to have a business plan. Has to list their competitors like HTC and Meta who are anticompetitively working together on a virtual world. viveverse is literally called metaverse; technically i don't know if it's literally the same virtual world.
You can then look at Lenovo, Microsoft, Valve and Google whose VR stuff died. Your assumption is they cant compete against them.
Then you explain your business plan of finding a wierd open source niche. Entirely because competing against meta is impossible.
I'm not saying fabricating evidence or like try to get your accounts banned off facebook to make it look like they are trying to crush you. You simply make the reasonable argument and business case a unresourced startup can't compete against a 350billion $ org with an army of devs.
Meta's fault for bothering you. Then again you're literally holding a paper vial of anthrax on this one if you do it. #YOLO
Yeah, don't go creating bullshit in response, but anyone who is remotely connected to anything Meta, Google, Apple are involved in should have in their documents details on why they won't be competing with the big names.
Courts aren't stupid - if it becomes apparent that you are attempting to maliciously comply, they can still get you based on your apparent intent.