Hadeed Carpet Cleaning filed suit in Virginia state court against the authors of seven reviews on Yelp that confirmed what many other reviewers were saying – that Hadeed advertises very low prices to lure consumers but always finds a way to charge more. Hadeed asserted that the seven defendants were actually a Hadeed competitor, not customers, and demanded their identifying information. A trial judge in Alexandria rejected Yelp’s objections to the subpoena and held Yelp in contempt. On appeal, we argue for Yelp that Yelp need not respond to a Virginia state court subpoena, but that Hadeed must get a subpoena from the California courts before Yelp, headquartered in San Francisco, can be ordered to comply, and that Hadeed has not come close to meeting the well-accepted First Amendment test for identifying anonymous speakers. The Virginia Court of Appeals affirmed the order enforcing the subpoena, reasoning that the statutory standard in Virginia Code Section 8.01-407.1 allows discovery based merely on the plaintiffs’ representation that it has conducted an investigation and has not reason to believe that the anonymous statements about it are true.