Co-Ops—Libel—”Common Interest” Privilege Inapplicable Since Statements Were Also Published to Many People Who Did Not Have a “Common Interest”—Malice and Excessive Publication Exceptions—Limited Purpose Public Figure Privilege Inapplicable—”Pure Opinion” Defense Rejected—Federal Communications Discovery Act Inapplicable

A co-op corporation (co-op) and its president and chairman of its board of directors (board), who is also an attorney, commenced a libel action against defendants. The defendants had moved to quash a subpoena duces tecum that the plaintiffs had served on non-party Google, Inc. and to dismiss the complaint on the grounds that the complaint failed to state a cause of action and failed “to plead with the requisite particularity.”

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