Rajagopal v. Does
This case involved a subpoena from a San Francisco plastic surgeon to an Internent service provider for the identities of five anonymous individuals who negatively reviewed the doctor on an Internet forum. The San Francisco Weekly published a lengthy article about the doctor in which it suggested that she had hired a consultant who manufactured positive online reviews for the doctor’s business. The article also stated that the doctor was on probation for allegedly putting a patient into a vegetative state due to her “gross negligence” and “unprofessional conduct.” Several people referenced the article on an online forum, including two former patients who shared their negative experiences. The doctor’s complaint alleged that the individuals “conspired together” to “engage in a campaign of unlawfully defaming and spreading lies about [her].” On behalf of the defendants, Public Citizen and the Virginia ACLU filed a motion to quash the subpoena and to sanction the doctor and her attorney. The motion was resolved when plaintiff dropped his lawsuit against the anonymous defendants.