Following a $3 million settlement against eBay, a federal judge in Massachusetts weighed in on a related case to determine if Massachusetts or California laws apply to punitive damages stemming from an alleged harassment campaign against a couple who wrote critical reviews about the e-commerce company.

In a Nov. 1 decision, U.S. District Judge Patti B. Saris of the the District of Massachusetts concluded plaintiffs Ina and David Steiner weren’t entitled to punitive damages on their claims for defamation, trespass, false imprisonment, and Massachusetts Civil Rights Act violations, which fell under Massachusetts law. However, their claims against eBay for torts of intentional infliction of emotional distress and civil conspiracy fell under California law, paving the way for potential damages.