Ninth Circuit Knocks Down Unfair Competition Case Against Yelp!

For those few of you who don't know already, Yelp! ("Yelp") is a wildly popular website where people can share their reviews, opinions, experiences, and ratings of businesses across the country. This service is invaluable when investigating new restaurants, dog walkers, dry cleaners, etc. However, it is important to take the reviews with a grain of salt because, no matter how great a store is, there will always be a few disgruntled customers, and, reportedly, it is becoming more and more common for competitors to post fake negative reviews and for employees to post fake positive reviews.

Recently, in Levitt v. Yelp!, Inc., a group of small business owners took the issue of online review manipulation one step further and alleged that Yelp itself was manipulating the reviews in an attempt to extort the businesses into purchasing ads. According to the plaintiffs, Yelp offered advertising services to the plaintiffs and, when the plaintiffs failed to purchase