Nefario and Goat, please tell us why you won't submit to paid, legally binding mediation through a neutral third party such as
http://judge.me?
Binding mediation is an oxymoron. If you mean binding arbitration, one huge issue is that it wouldn't bind the asset holders, so it wouldn't solve the main problem. It could solve the issue of Goat getting back listing fees or any funds of his that Nefario or GLBSE is holding. But it wouldn't solve the real problem whose victims are the asset holders, not Goat, and not Nefario. Also, since Goat doesn't have anything Nefario/GLBSE is claiming they are entitled to, what benefit what Nefario/GLBSE gain from agreeing to this?