"But this perception is inherently unfalsifiable. It is hard to imagine a more personal and subjective feeling than how one views their own childhood.
"Moreover, Plaintiff's opposition completely ignores the context of the statement, where Ms Winfrey asked Meghan about her 'relationship' with Plaintiff (to whom Ms Winfrey referred as her 'half-sister on her father's side').
"Meghan's response to that question that she 'grew up as an only child' was obviously not meant to be a statement of objective fact that she had no genetic siblings or half-siblings.
"Rather, it was a textbook example of a subjective statement about how a person feels about her childhood."
Samantha is also taking action over claims made in Omid Scobie and Carolyn Durand's biography of Meghan and her husband Prince Harry, but the duchess' lawyers insisted she cannot be sued over the tome, Finding Freedom, because she didn't write it.
The 57-year-old writer had argued Meghan made statements in the book via a third party, but the royal's lawyers insisted the undisputed authorship of Scobie and Durand is the "death knell for all claims against Meghan based on statements in the book".
They argued: "Meghan did not make the statements; she cannot be liable for them. It is that simple."
As well as arguing for a dismissal, the lawyers are also looking for Meghan - who has children Archie, three, and Lili, 13 months, with Harry - to have her costs covered.
They told the court: "In sum, Meghan's motion to dismiss should be granted, as should her request for attorneys' fees, costs and other relief."