Alleged “Conspiracy” Among Disgruntled Ex-Employees Defeats Section 230–Tanisha v. Chandra

4 04 2016

Eric Goldman, March 31, 2016

[Note: as I’ve mentioned before, sometimes Westlaw randomly spits out cases months after they were issued. This opinion is 4 months old but just appeared in my Westlaw alerts this week. Despite its age, I’m blogging it because of its topicality.]

Prakash Chandra worked for Tanisha Systems but left. Tanisha alleges that Chandra and another disgruntled ex-employee, Ashwini Jayaprakash, jointly and vengefully schemed to harm Tanisha’s reputation; Jayaprakash allegedly said “his goal was to ‘screw’ the company and put it out of business.” Tanisha alleges that Chandra and Jayaprakash collaborated by:

jointly developing the hit list of former and current employees, requested confidential information from the individuals on the hit list, and combined to use social media to infect search results concerning Tanisha Systems.

Their alleged initiative included a blog,, published in Jayaprakash’s name but allegedly:

Chandra commented on the blog site, “vouching for the correctness of the content by praising the author as … having shown ‘the real picture of Tanisha Systems,’” and emailed the blog post’s link to Tanisha Systems employees on his “hit list,” urging them to forward the blog and share it widely

On its face, as I discussed in my Co-Blogging Law article from a decade ago, Chandra looks well-positioned for a Section 230 defense. Tanisha seeks to hold Chandra liable for endorsing Jayaprakash’s content and promoting it, and the court emphasizes that Section 230 applies “to most (and perhaps all) of Defendant’s conduct in forwarding the blog post and providing commentary supportive of its contents.” The court also says that “this is a Complaint with problems.” Yet, the court denied Chandra’s motion to dismiss. Why?


Case citation: Tanisha Systems, Inc. v. Chandra, 2015 WL 10550967 (N.D. Georgia Dec. 4, 2015)

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