Jane Doe, an anonymous blogger and author of the website Pogo Was Right: Privacy News from Around the World, filed suit in the Central District of California against Lillian Glass, Ph.D. The lawsuit seeks a declaratory judgment that (1) Doe is protected by Section 230 of the Communications Decency Act from liability for postings made by anonymous third parties in the website's forums, and (2) that certain comments made by Doe on the blog do not defame Dr. Glass.

The case arises from a series of posts by Doe on the Pogo Was Right website relating to the mental health problems experienced by Britney Spears and the resulting media coverage. Dr. Glass, a "body language expert," had appeared on CNN's Showbiz Tonight and on CNN's Primetime Live with Erica Hill to discuss Ms. Spears' behavior and to offer a potential diagnosis of Ms. Spears as suffering from Multiple Personality Disorder. In response, Doe authored a series of posts criticizing Dr. Glass' comments and raising concerns about Ms. Spears' privacy and patient confidentiality.

On June 18, 2009, an attorney for Dr. Glass wrote to Doe, asserting that certain comments by Doe and an anonymous forum poster "violated the privacy rights and other rights" of Dr. Glass; were "false and defamatory in nature, and [were] designed to embarrass and hold my client up to ridicule"; and "incited persons with such propensities and have called for Dr. Glass' death." (The latter in reference to the following from one of Doe's posts:  "'Dr. Phil' catches some flak and dishes some out A complaint filed about Dr. Phil -- but is it wellfounded? People who live in Glass psychology houses shouldn't throw stones. They should be stoned. Dr.
Lillian Glass backpedals, but is it too little, too late?") The letter demanded that Doe remove all references to Dr. Glass from her posts.

Dr. Glass' attorney subsequently sent an email once again threatening to sue if Doe did not remove the references to Dr. Glass from the webiste. The email also stated: "I should also mention to you that if a suit is filed against you, then there will be a public record of your identity and of your capacity as the blogger of this 'pogowasright.org' and other websites. Since you have gone to such great lengths to hide your identity improperly, I think this should also be a concern of yours." Doe filed the complaint for a declaratory judgment ten days after receipt of this email.

Aleksandra Vinogradov, a professor at Montana State University, subpoenaed the Bozeman Daily Chronicle for information concerning comments made on the Chronicle's website in connection with two articles published in March and April 2009 regarding the trial in Vinogradov's gender discrimination suit against her employer, Montana State University.

Vinogradov sought this information to support a request for a new trial in her discrimination lawsuit against MSU, which ended in a jury verdict against her in April 2009. Her attorneys argued that one of the commenters to the April 2009 article who posted under the pseudonym “mbcomstock” was Brandon Comstock, one of the jurors in the case. The comment in question read: "Note that this was the third time this same woman has sued the university for discrimination, and her third loss. Maybe, just maybe, instead of everybody else being conspiring liars hiding a ‘big dirty secret,’ the problem is really her." In a May 2009 hearing, Comstock testified that he was not the author of the comment, but acknowledged that his father might have written it.

Vinogradov claimed this post proved the jury was improperly informed of her prior suits against MSU. She moved for a new trial based on jury misconduct and served a subpoena on the newspaper requesting that the Chronicle turn over:

"1) copies of all postings made to the Chronicle's website or blog relating to the two articles; 2) the names and identities off [sic] persons and organizations that posted such comments; 3) the IP addresses associated with each comment posted; 4) the IP addresses associated with each viewer of the two articles during the period of March 23, 2009 to April 3, 2009; 5) all computer logs generated in connection with the two articles; and 6) any and all e-mail communications and other written communications that the Chronicle and its website, its agents and its employees have received or sent on or after March 23, 2009 relating to the two articles." 

Ruling at 2. In addition, Vinogradov filed an emergency motion to perpetuate testimony pending appeal, so that information on the posting could be considered with her request for a new trial. 

On June 3, 2009, the Chronicle opposed Vinogradov's motions, arguing that the information and documents she sought "are protected under Montana's Media Confidentiality Act, specifically  26-1-902, MCA." Ruling at 3. The next day, MSU also opposed Vinogradov's motion to perpetuate, arguing that "the information she seeks is not relevant to the jury misconduct issue" and therefore did not satisfy procedural requirements. Id. 

On June 5, 2009, the court denied Vinogradov's motion to perpetuate testimony pending appeal on procedural grounds. The court did not address the newspaper's shield law argument or rule on its motion to quash the subpoena.  Later in June, the court denied Vinogradov's motion for a new trial. 

Vinogradov reportedly will appeal this result. 

The Guardian Civic League has filed a class-action lawsuit on behalf of 2,300 black Philadelphia police officers against the Philadelphia Police Department for allegedly allowing its officers to post racist and offensive content on Domelights.com, a website focused on law enforcement. 

Guardian's three-count complaint claims that the Philadelphia Police Department engaged in the creation of a hostile work environment on the basis of race (42 U.S.C. § 1983), discrimination (42 U.S.C. § 1981), and conspiracy to interfere with civil rights (42 U.S.C. § 1985) when white officers, Does 1-10,000, posted racist content to the forum site.  

Guardian alleges that "an Active Duty Philadelphia Police Sergent" with the username 'McQ' founded and operated . . . . [t]he racially offensive website." Compl. ¶ 3. Guardian attached screenshots of various posts from Domelights.com, reading "Guns Don’t Kill People. Dangerous Minorites Do. How much longer can you ignore this?" and "adults can't speak proper English or spell at a 3rd grade level, but they can sing among 'theyselves' to lyrics of a rap song." Compl. ¶¶ 2, 7.  Guardian asserts that these "offensive postings . . .  are part of the intentional purpose of the creator of Domelights.com Sgt. 'McQ.'" Compl. ¶ 8.

Guardian asserts that "White police officers use Domelights.com at work, in front of African American Police Officers, and discuss the contents of this racist website, make jokes about it. "Compl. ¶ 5. Also, Guardian argues that the Police Department is aware of the website but although "African American Police Officers have complained to the Philadelphia Police Department regarding Domelights.com,  . . . no actions have been taken to restrict this website or to discipline those police officers responsible for its racially offensive and legally violative content." Compl. ¶ 48.

Guardian seeks a ban on "the operation and use of Domelights.com by Philadelphia Police Officers" as well as compensatory and punitive damges.  Compl. ¶ 10.

The Philadelphia police have not yet filed an answer to the complaint. 

Attorneys at Favaro & Gorman Ltd. filed a lawsuit against Jennifer Meale and Xcentric Ventures, LLC over allegedly defamatory posts made anonymously by Meale on Ripoff Report, a consumer review website.  It is not clear how the law determined that Meale was responsible for the anonymous reports.

According to the Northwest Herald, Xcentric was named as a defendant because it failed to remove the allegedly defamatory postings despite repeated requests from Favaro & Gorman.  Xcentric will likely raise section 230 of the Communications Decency Act as a defense.

According to the Hudson Reporter, in September 2008 the Town of Secaucus sought a subpoena from a Hudson County Superior Court judge to force NJ.com, a website run by a group of New Jersey newspapers, to disclose the identities of several anonymous posters going by 2Advil, AllEyzOnYou, and Truth4Tel. These individuals allegedly posted defamatory comments related to a political dispute within the town council.  The CMLP has not been able to determine whether the subpoena issued, whether NJ.com complied, or whether a lawsuit was ultimately filed. 

Skutt Catholic High School sued anonymous Wikipedia posters over critical edits posted to the school's Wikipedia page in 2006. The posts criticized the quality of education at the school and its high tuition, used vulgar language, and referenced student drug use. After filing suit, the school subpoenaed Cox Communications, the ISP for the IP addresses used to make the postings. A spokesman from Cox Communications told the Student Press Law Center that the company would comply with the subpoena "unless there are further developments in the case, which quashes that order." The CMLP has been unable to determine whether Cox Communications ultimately complied and what ultimately happened in the underlying lawsuit.

On February 13, 2009, Tim Blixseth, a real estate developer and shareholder in the bankrupt Montana ski resort Yellowstone Club, filed a complaint in Massachusets federal court against Bresnan Communications, a New York-based ISP, and 100 unnamed defendants.  The complaint sought a declaratory judgment that Blixseth was entitled to obtain from Bresnan Communications the identity of one of its subscribers, an anonymous commenter to the NewWest.net website going by the moniker "Sharkbait."

Blixseth alleged that Sharkbait made a death threat against him in the comments section to an NewWest article on the Yellowstone Club bankruptcy. Counsel for Blixseth contacted NewWest shortly after the alleged death threat was posted, and the site's publisher agreed to remove the comment and disclose Sharkbait's IP address.

The same day the complaint was filed, Blixseth served a subpoena on Bresnan Communications requesting that it provide identifying information for Sharkbait's IP address.  Counsel for Bresnan Communications objected to the subpoena, citing federal law prohibiting cable operators from divulging customer information without a court order and notice to the subscriber.

Blixseth then filed an emergency motion seeking an order requiring Bresnan Communications to turn over the requested information and a motion to seal.  The district court subsequently denied both motions.  There has been no activity on the docket since mid-February 2009.

Lawyers from the Healthcare Information Management and Systems Society (HIMSS), a health care industry trade group, sent letters to two bloggers demanding that they remove allegedly offensive and defamatory user comments, provide any information that may help in the identification of the comment posters, and preserve all records relating to the posters.  Specifically, the letters concern a comment by “Rocky Ostrand” on Chip Hart's blog, “Confessions of a Pediatric Practice Consultant,” which is hosted at pedsource.com, a service provided by Physician's Computer Company (PCC); and comments by “Calvin Jablonski” on the blog of Chilmark Research.

Both bloggers have posted responses to the letters, refusing to remove the allegely defamatory comments or provide information to aid in identifying the potentially pseudonymous commenters.  Both have, however, offered to post any response to the comments which HIMSS may wish to make.  At this point, it does not appear that HIMSS has taken either blogger up on this offer.

Remove Your Content LLC, which bills itself as a "targeted adult content removal service," filed suit in federal district court in Texas against 20 unnamed defendants for defamation, business disparagement, tortious interference, assault, and trademark infringement.

Remove Your Content's claims stem from a series of anonymous blog posts (on the now-defunct websites ericgreensuck.blogspot.com and removeyourcontent.blogspot.com), forum comments (NSFW), and emails directed at Remove Your Content and its owner, Eric Green. According to the Complaint, the complained-of communications contain both physical threats against Mr. Green ("We tried to pay a visit to you dude," Complaint Ex. 1 and "Either quite (sic) bothering all these sites and blogs or will (sic) take the bet and nuke you with an early Christmas present," Complaint ¶7), and false and defamatory statements about Remove Your Content's business practices ("He gets paid by other sites (sic) owners to take down pirated content. However he does it in a totally illegal matter (sic)," Complaint Ex. 2 and "Most of his DMCA (sic) are not legid (sic) because he would reported (sic) unlicensed material or matrial (sic) he doesn't even own (sic) its copyright," Complaint Ex. 2).

Remove Your Content seeks exemplary damages and attorneys' fees in excess of $100,000, as well as preliminary and permanent injunctions barring the defendants from contacting Plaintiff's place of business, employees, and clients, and from making false and defamatory statements about Plaintiff and Plaintiff's employees. Further, Remove Your Content has indicated its intent to seek discovery to uncover the identities of Does 1-20 ("Plaintiff now sues in order to discovery and verify the identities of the Defendants and recover damages." Complaint ¶11)

The blogs involved --  ericgreensuck.blogspot.com and removeyourcontent.blogspot.com -- have been removed, and cached copies are no longer available on Google.