MP v. Does [1]

Proceeding anonymously, the owner of a country club located in Del Mar, California filed a petition in Texas state court seeking pre-litigation discovery from Google, arguing that "derogatory statements" about her had been posted on "blogs hosted by Google." The Texas state court granted MP permission to issue subpoenas to Google, and she issued subpoenas seeking the identies of the creator of the Del Mar Country Club Sucks blog and all persons who posted comments there. 

Google notified the creator of the blog, who moved to quash the subpoena.  Public Citizen and the ACLU submitted an amicus brief [2] in support of the motion to quash, arguing that the country club owner had not justified filing suit in Texas over comments on a blog about a California country club, and that the country club owner had not produced sufficient evidence to overcome First Amendment protection for anonymous speech. The court granted the country club owner permission to amend her petition to meet the standard required by the First Amendment, but she failed to come forward with sufficient allegations or evidence, and the court granted [3] the motion to quash the subpoena.