Jones v. Meta Platforms, Inc.
3:25-mc-80165
| N.D. Cal. | Aug 11, 2025Background
- Stephanie Jones and Jonesworks LLC filed a defamation lawsuit in the Southern District of New York against several parties, including anonymous "Doe Defendants," for an alleged coordinated smear campaign.
- The Doe Defendants are accused of creating defamatory websites and fake social media accounts targeting Jones and her company.
- Petitioners served subpoenas on Meta Platforms, Inc. (Facebook) and Pinterest, Inc. seeking user account information to identify the anonymous Defendants.
- Respondents (Meta and Pinterest) objected to the subpoenas, arguing that disclosure would violate the First Amendment rights to anonymous speech.
- Petitioners moved to compel compliance with the subpoenas in the Northern District of California, where Meta and Pinterest are headquartered.
- The central tension is between First Amendment protection for anonymous speech and the ability of plaintiffs to identify and hold accountable those responsible for alleged defamation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is user account info protected by the First Amendment? | No First Amendment protection for user account/subscriber info; First Amendment does not apply | Subscriber info is presumptively protected; disclosure infringes on anonymous speech | User account info is presumptively protected by First Amendment |
| Have plaintiffs made a prima facie case for defamation? | Yes; competent evidence of defamation per se as private figures | Plaintiffs are limited-purpose public figures; proof of actual malice required and missing | Plaintiffs established a prima facie case as private figures (no actual malice needed) |
| Should the court compel compliance despite First Amendment interests? | Balance favors disclosure; critical to identify perpetrators; no alternative means | No compelling need; plaintiffs have not met threshold to override First Amendment | Balancing test favors plaintiffs; court compels Meta and Pinterest to disclose info identifying the Doe Defendants |
| Does the request for Pinterest user agreements warrant production? | Not addressed in motion or reply | Irrelevant and unduly burdensome | Court denies motion only as to Pinterest user agreements |
Key Cases Cited
- McIntyre v. Ohio Elections Comm'n, 514 U.S. 334 (U.S. 1995) (First Amendment protects anonymous speech)
- Gertz v. Robert Welch, Inc., 418 U.S. 323 (U.S. 1974) (Defamation law distinguishes between public and private figures)
- Reno v. American Civil Liberties Union, 521 U.S. 844 (U.S. 1997) (Online speech receives same First Amendment protection as other speech)
- Dillon v. City of New York, 704 N.Y.S.2d 1 (N.Y. App. Div. 1999) (Defamation elements under New York law)
- Milkovich v. Lorain J. Co., 497 U.S. 1 (U.S. 1990) (Defamation and the First Amendment)
- Frechtman v. Gutterman, 979 N.Y.S.2d 58 (N.Y. App. Div. 2014) (Defamatory per se includes harm to profession)