Neibich v. Reddit: Screenwriting-Contest Operator Sues an r/Screenwriting Moderator and 50+ Users
2020
After r/Screenwriting users called certain screenwriting competitions scams, the contests' operator sued the subreddit's volunteer moderator and 50+ unnamed users for defamation; the moderator was dismissed under Section 230.
What happened
In 2019, members of r/Screenwriting began warning each other that certain paid screenwriting competitions appeared fraudulent. The operator of those competitions, Joseph Neibich, responded by filing suit in March 2020 in the Superior Court of Los Angeles County (Neibich v. Reddit, Inc., No. 20STCV10291) against Reddit, the subreddit's volunteer moderator, and more than 50 unnamed community members. Beyond defamation, the complaint asserted intentional interference with economic advantage and infliction of emotional distress, and faulted the moderator for 'pinning' the critical posts and continually commenting on and updating the thread.
Because Ninth Circuit case law broadly interprets Section 230 of the Communications Decency Act, the moderator was dismissed from the case roughly two months later, in May 2020, on the theory that curating and pinning third-party posts is protected publisher activity. The unnamed Doe users would have been reachable only through identity discovery.
The case later gained prominence beyond the subreddit: Reddit cited it in its 2023 amicus brief to the U.S. Supreme Court in Gonzalez v. Google as a concrete example of how Section 230 shields volunteer moderators and ordinary users from being dragged into expensive litigation over community speech.
Impact
A widely cited illustration of how a single aggrieved business can use a defamation suit to target a volunteer moderator and dozens of anonymous Redditors; also became a Section 230 talking point in Reddit's Supreme Court advocacy.