Yelp! Reviewer’s Identity Not Discoverable Absent Comments That Were Defamatory

An anonymous author of a critical online review of an apartment complex management company need not be identified in a civil discovery-petition proceeding because the management company did not allege an actionable defamation claim, the Illinois Appellate Court, First District, ruled Jan. 31 (Brompton Building LLC v. Yelp! Inc., Ill. App. Ct., 1-12-0547, 1/31/13).

It is critical to read allegedly defamatory statements in context to discern their meaning, the court said in an opinion by Justice James R. Epstein. Here, the court added, when the poster known as Diana Z.'s comments on Yelp! were read in their ...