This case involves comments made by participants on InvestorsHub.Com, a membership-only website designed for serious investors. The comments at issue appear on a message board dedicated to one specific subject matter: the plaintiff, Treaty Energy Corporation (TECO). Several participants on the message board criticized TECO’s press releases for being “fluff,” “nontransparent,” or even containing outright lies. Some of those same participants referenced an ongoing bankruptcy matter in which a principal TECO shareholder has been accused of various wrongdoings. TECO responded by filing a defamation action in the Eastern District of Louisiana and subpoenaing InvestorsHub.Com for the identities of the defendants. On behalf of two of the Doe defendants, Public Citizen successfully moved to quash the subpoena.