Forwarding Defamatory Email with Introductory Comments Protected by 47 USC 230–Phan v. Pham

26 02 2010

By Eric Goldman

Phan v. Pham, 2010 WL 658244 (Cal. App. Ct. Feb. 25, 2010)

This is the first 230 case I’m blogging about in 2010 (see my 2009 recap), and what a nice ruling to start the year. The facts are crisp and clean: An email author wrote an allegedly defamatory email about plaintiff Phan and sent it to a group of recipients, including defendant Pham. Pham then forwarded the email with the following additional comments to at least one recipient:


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