United States Ninth Circuit

Dismissal of an action brought by plaintiff small business owners, alleging that defendant extorted or attempted to extort advertising payments from them by manipulating user reviews and penning negative reviews, is affirmed, where: 1) under the Hobbs Act and California law, unless a person has a pre-existing right to be free of the threatened economic harm, threatening economic harm to induce a person to pay for a legitimate service is not extortion; and 2) plaintiffs did not allege sufficient facts to support their claim that defendant authored negative user reviews.

Appellate Information

• Decided 09/02/2014
• Published 09/02/2014

Judges

• Berzon

Court

• United States Ninth Circuit

Counsel