Ninth Circuit Criticizes Attempts to Plead Around Section 230–Kimzey v. Yelp

7 02 2017

[Note: Venkat represented Yelp in this case but was not involved in the preparation of this post.]

For all of the drama associated with Section 230 jurisprudence this year–including in the Ninth Circuit–it’s easy to forget that Section 230 still works well in simple cases when a plaintiff tries to hold a website liable for third party content. So it’s refreshing to get a straightforward Section 230 case that reaches the expected result. And it’s especially gratifying to see a court recognize–and reject–efforts to plead around Section 230.

The Opinion

Kimzey is a locksmith operating as Redmond Locksmith a/k/a Redmond Mobile Locksmith. “Sarah K” left a negative Yelp review of the business. Kimzey sued Yelp pro se. The district court easily tossed the lawsuit. The Ninth Circuit affirms.

Case citation: Kimzey v. Yelp!, Nos. 14-35487 & 14-35494 (9th Cir. Sept. 12, 2016)


The content in this post was found at and was not authored by the moderators of Clicking the title link will take you to the source of the post.



Leave a comment

You must be logged in to post a comment