Question
Yelp, Inc., is a California company that operates a social net-working website for consumer reviews. Seven users of Yelp posted negative reviews of HadeedCarpet Cleaning,
Yelp, Inc., is a California company that operates a social net-working website for consumer reviews. Seven users of Yelp posted negative reviews of HadeedCarpet Cleaning, Inc., in Alexandria, Virginia. Hadeed brought a defamation suit against the "John Doe" reviewers in a Virginia state court, claiming that because these individuals were not actual customers, their comments were false and defamatory. Yelp failed to comply with a court order to reveal the users' identities and was held in contempt. Yelp appealed, claiming that releasing the identities would violate the defendants' First Amendment right to free speech. A state intermediate appellate court affirmed the lower court's judgment, but that decision was reversed on appeal. The Supreme Court of Virginia ruled that even though the state trial court had jurisdiction, it did not have subpoena power over Yelp, a nonresident defendant. According to the court, "Enforcement of a subpoena seeking out-of-state discovery is generally governed by the courts and the law of the state in which the witness resides."
Note: Can you please answer this question using IRAC( Issue, Rule of Law, Analysis, and Conclusion) format. Because then it will be easy for me to understand the case a a lot better. Please explain.
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