College Review Website Ordered To Pay $1M For Users’ Disparaging Reviews–Neumont University v. Little Bizzy

15 12 2014


Before the headline freaks you out too much, let me highlight the most important fact: this is a default ruling. The defendant was a company but it says it couldn’t find cost-effective counsel, so the company’s principal tried to defend the company’s interests in court individually–a procedural no-no. So the court tosses all of the defendant’s efforts, and the defendant company no-shows for the rest of the proceedings. The result is an unopposed default judgment motion, and as we know, usually those don’t end well for defendants.

The case involves Collegetimes, a website that lets users review colleges. The website has a review page for Neumont University, a for-profit college based in Utah. The page is filled with critical reviews, such as “This school can be summed up in 3 words ‘PIECE OF SHIT.’” The page also has comments indicating that some prospective students reconsidered their interest in Neumont after reading the reviews. The opinion indicates that Neumont tried to post responsive comments, but that triggered Collegetimes to include a banner saying “Warning: We recommend that you avoid this college.” Neumont also alleged that the site deleted positive reviews, blocked Neumont’s ability to access its discussion forum on the site, and posted disparaging tweets such as “# Neumont student reveals that administrators host ‘pizza parties’ to coax students to leave positive reviews online”

Neumont claims it lost at least 12 matriculants due to Collegetimes, resulting in $1.02M of lost revenues ($85k/student). How does one prove that negative online reviews from one particular website are the legally responsible cause of a company’s lost revenues?

Case citation: Neumont University, LLC v. Little Bizzy, LLC, 2014 WL 2112938 (D. Nev. May 20, 2014). A backgrounder on the case. For more filings in the case, see Justia, Scribd and SCU’s Digital Commons.


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