C.A. 1st;
A143680

The First Appellate District reversed a judgment and remanded. The court held that a plaintiff was required to prove the falsity of alleged libelous statements in anonymous internet reviews in order to compel disclosure of the speakers' identities.

Seven persons claiming to be current or former employees of ZL Technologies, Inc. posted reviews of ZL on the Glassdoor website. ZL sued the seven Doe defendants for libel. ZL thereafter served a subpoena on Glassdoor, Inc., seeking disclosure of the anonymous users' identities and contact information. When Glassdoor refused to comply, ZL moved to compel Glassdoor to disclose the requested information.