First Circuit Rejects Copyright Workaround to Section 230–Small Justice v. Ripoff Report

27 12 2017

Goren runs a law firm, Small Justice. DuPont, a defendant in a case Goren brought, posted two negative reviews about Goren to Ripoff Report. Goren sued DuPont, who no-showed, resulting in  default judgment. The state court awarded DuPont’s copyright in the two reviews to Goren. Goren then asserted the copyright against Ripoff Report. We have been covering this case for years (since 2013!). My blog post on Goren’s initial complaint. Venkat’s post on the initial district court ruling. My post on a subsequent district court ruling.

On appeal, the First Circuit sides completely with Ripoff Report. Barring an ill-advised appeal to the Supreme Court, this case should be over.

Section 230. Section 230 wipes out Goren’s defamation, intentional interference and (parts of) unfair competition claims based on DuPont’s negative reviews.

Copyright. Ripoff Report claims that DuPont granted it an irrevocable nonexclusive license, so Goren never had the right to terminate the license or claim Ripoff Report was infringing.




Case citation: Small Justice LLC v. Xcentric Ventures LLC, 2017 WL 4534395 (1st Cir. Oct. 11, 2017)

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