iXL Enterprises v. Doe [1]

iXL Enterprises, an Internet consulting company, sued to obtain the identity of an anonymous internet poster who criticized the company on a Yahoo! message board.  iXL claimed that the defendant was an iXL employee, and that the internet postings violated his/her employment agreement.   

iXL obtained a subpoena to force Yahoo! to reveal the identity of the anonymous user.  The Doe defendant moved to quash the subpoena, arguing that he/she was not an iXL employee and that the First Amendment protected his/her right to speak anonymously.  According to cyberSLAPP.or [2]g, "the case was not pursued to decision" because iXL went out of business.