A city in Ohio and its police chief sued several anonymous critics, claiming that the critics defamed the police chief in Facebook comments and an email message. The police chief then moved to seek discovery in California (from Facebook) and Switzerland (from the email provider). In January 2023, Public Citizen filed an amicus brief urging application of the Dendrite standard to the motion. In a decision issued in April 2023, the trial court adopted a modified form of the Dendrite standard, requiring notice to the anonymous users and evidence supporting the elements of the prima facie case. The court then denied discovery on the ground that all of the statements at issue were protected opinion under Ohio law. The plaintiffs then dismissed the case.