Matrixx Initiatives v. Barbary Coast Capital [1]

Anonymous users posted negative comments about Matrixx Initiatives on the Yahoo! Finance and Silicon Investor message boards. Matrixx filed a lawsuit against the anonymous "John Doe" posters in an Arizona court alleging defamation and other claims. Matrixx received information from Yahoo! that some of the postings could be traced to computers owned by Barbary Coast Capital Management, LLC, a San Francisco hedge fund. Matrixx got permission from the Arizona court to take a deposition in California of Stephen Worthington, a manager at Barbary Coast. During the deposition, counsel for Matrixx asked Worthington about the identity of the anonymous posters, and he refused to reveal their identity or to say whether he was one of them. Matrixx obtained an order from the Santa Clara Superior Court in California requiring Worthington to answer the questions.

Barbary Coast and Worthington appealed the trial court's decision, claiming that it violated the posters' First Amendment right to speak anonymously. The appellate court affirmed the decision of the trial court, holding that Barbary Coast and Worthington lacked the standing to assert the First Amendment rights of the anonymous posters.