The problems of those online reviews. The number of stars, or lack thereof, can make or break a business. Consider Joe Hadeed's carpet cleaning business. A slew of negative reviews about his work began cropping up on Yelp in 2012.220 Yelp is a Delaware corporation with its principal place of business in California. Yelp is a social-networking website that allows its users to post and read reviews on local businesses. In the first quarter of 2013, Yelp had an average of approximately 102 million monthly, unique visitors. Contributors to Yelp have written over 39 million local reviews.

Yelp users must register to post reviews. The registration process requires users to provide Yelp with a valid e-mail address. Users are then free to choose a screen name to use when posting their reviews. Yelp further allows users to designate a zip code of their own choosing as their location. Yelp does not require users to use their actual name or place of residence. Yelp typically records the Internet Protocol ("IP") address from which each posting is made. This information is stored in Yelp's administrative database, which is accessible to Yelp's custodian of records in San Francisco.

During registration, Yelp users are required to agree to Yelp's Terms of Service and Content Guidelines ("TOS"). The TOS require users to have actually been customers of the business in question before posting a review. The TOS further require users to base their reviews on their own personal experiences. Yelp may remove posts that it deems in violation of the TOS. Moreover, Yelp employs a proprietary algorithm to filter potentially less reliable reviews.

After Mr. Hadeed's business evaluations on Yelp, business was down by \(30 \%\). Eighty employees were laid off, and six cleaning trucks sold. Mr. Hadeed, who has run a successful business for a number of years, filed suit against the seven Yelp reviewers. He wanted their true identity, but Yelp refused. The trial court ordered subpoenas served on Yelp and compelled the company to respond with the identities and other records. Yelp appealed the decision and the decision was affirmed. \({ }^{221}\) However, Virginia's Supreme Court, relying on basic civil procedure, held that Virginia courts did not have jurisdiction over Yelp. \({ }^{222}\)..................

Discussion Questions 1. What can you think of as a defense for someone who posts a review and whose identity is revealed to the business?
2. Discuss the ethics of companies whose business it is to write negative reviews for competitors in order to increase business?
3. Evaluate whether you have been fair in your own posted evaluations of businesses. If you were the business owner, how would you feel about the review that you wrote?