Apoha in Dharmottara

I am presently attending a thought-provoking workshop on apoha, held in Vienna, Akademie der Wissenschaften. The programme of the workshop is to read Kumārila's refutation of apoha as depicted in Jayanta's Nyāyamañjarī and then Jayanta's depiction of the Buddhist reply.
Kumārila must refer to Dignāga's theory (since he did not know Dharmakīrti's one), whereas the reply in Jayanta is Dharmottara's one.

Dignāga's and Dharmottara's theories seem to be utterly different. Dignāga, Ole Pind (who authored a PhD thesis on Dignāga's theory of apoha, available online here) informed us, really defines apoha as abhāva (absence) and vyāvṛtti (exclusion) and uses it as if it were the exact equivalent of a positive universal (which he cannot accept for inner-Buddhist reasons). But an apoha so conceived can be easily attacked insofar as it posits the external existence of an absence.
Dharmakīrti, in order to avoid Kumārila's criticism, defined apoha as an internal image. But
Dharmottara adjusts this position by saying that apoha is neither external, nor internal. Why? It cannot be external because it is not real, nor can it be internal, because it is not of the nature of cognition (abodharūpatvāt, in Jayanta, NM 5, section 2.6 in Kataoka's 2009 edition). What is it then? I would suggest that it can well be an action, that of excluding. But Dharmottara (as represented by Jayanta) rather says focuses on apoha as the āropitākāra ("externalised image", i.e., the result of the action of negating anything else which is projected on the outside) and says that it is nothing at all (na kiñcid eva). Why is this āropitākāra not of the nature of cognition? Because it is the externalised image, which is no (longer) a mental event.

In this way, all objections against it are easily defeated (since both the arguments against an external apoha and against an internal apoha become pointless). But the solution seems somehow paradoxical. Of course, Dharmottara can reply that this is due to the fact that this solution regards the worldly level (vyavahārika) and not the ultimately real one (paramārthika).

On Jayanta, see this post. On apoha, see this one.