In-house lawyers are not happy with a recent appeals court decision requiring the online review site Yelp to remove certain reviews that have been deemed defamatory. These critics say the decision flies in the face of the protections provided by Section 230 of the Communications Decency Act, which immunizes internet companies from liability based on content created by third parties.

Back in 2012, Ava Bird hired San Francisco-based personal injury attorney Dawn Hassell to represent her. Due to some communication issues, Hassell withdrew from representing Bird less than a month later. The former client later published a negative review on Yelp, giving Hassell a one-star rating. Bird refused to remove the review and then allegedly posted another bad review using a fake Yelp identity. Hassell sued, claiming defamation and other causes of action.

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