The court heard Mr Steele was aware that former US state department official David Kramer was in contact with a Buzzfeed journalist after receiving inquiries about his work, but had not expressly requested that they meet.
Mr Kramer – without the knowledge of Mr Steele – then allowed the reporter, Ken Besinger, to look at the dossier but had not agreed to him photographing the contents, which were then send on to his editors.
“(His) conduct in photographing the Dossier was not only unauthorised, it was expressly prohibited by Mr Kramer”, said the judge. “It was that wrongful conduct that led directly to the publication of the BuzzFeed Article.”
Some of the contents of the dossier, which comprised 35 pages of raw intelligence data, have been confirmed, but other claims about Trump remain unverified.