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Showing posts with label FaceBook. Show all posts
Showing posts with label FaceBook. Show all posts

Friday, 13 May 2011

Anonymity order by English court refers to Twitter and Facebook

On 12 May 2011 the English Court of Protection referred to Twitter and Facebook in an order made to prevent publication of the name of a person who was the subject of proceedings.   The problem is - Twitter and Facebook are companies operating from the United States and are therefore removed from direct sanction by the English courts.

Kevin Rawlinson, on The Independent newspaper website, reported a Facebook spokesman as commenting that Facebook’s  lawyers were “reviewing” the order and a Twitter spokesman as declining to comment on the order but did note that the Twitter terms of use require users to comply with “all applicable local, state, national, and international laws, rules and regulations”.[1]

The circumstances in which the English court made the order in that an application was made to the U.K. Court of Protection to withdraw all life-sustaining treatment  for a woman  referred to as “M”, who contracted brain stem encephalitis, which had the effect that she is described as a being in a “minimally conscious state”.   The court proceedings followed family members reaching the view that “M” would not wish to continue living in her current state and that it is not in her interests to do so. The Court of Protection has powers to assist those who, for whatever reason, lack the capacity to make decisions themselves. While the court usually conducts proceedings in private, however applications for permission to withdraw nutrition and other cases involving issues of life and death are usually held in open court.  Mr Justice Baker issued orders, pursuant to rule 92(2) of the Court of Protection Rules 2007,  as to how the proceedings could be reported, with the orders prohibiting “the publishing or broadcasting, in any newspaper, magazine, public computer network, internet site, social network or media including Twitter or Facebook, sound or television broadcast or cable or satellite programme service, of any information (including any photograph) that is likely to lead to the identification” of “M” and other people involved in the application to the court.  Service of the notice was directed to be made:

(1) by service on such newspaper and sound or television broadcasting or cable or satellite or programme services or internet service providers as they think fit, in each case by fax or first class post or e-mail addressed to the editor (in the case of a newspaper) or senior news editor (in the case of a broadcasting or cable or satellite programme service) or website administrator or internet service provider (in the case of an internet service) or the administrator of any social network or media sites and/or to their respective legal departments; and/or
(2) on such other persons as the parties think fit, by personal service.

Members of the Twitterati who defy the court anonymity orders face contempt of court proceedings. What is less certain is the liability of the administrators (one assumes that is intended to describe the managers and operators of the social network sites) in respect of  informing users of the existence of the court order or in respect of the deleting of any post to social networking sites by users that breach the orders; or closing the accounts of users that defy court anonymity orders.

Roy Greenslade, of The Guardian newspaper, noted “that a Twitter spokesman told The Guardian that it does remove "illegal tweets and spam." So it has the technology to do the job.”[2] While it is also open to for administrators of any social network sites to close accounts of any person defying court orders that will be as the saying goes - after the horse has bolted.
This court order can be seen as a response the controversy over Twitter accounts being used to name (apparently incorrectly) celebrities that had obtained injunctions that included anonymity orders or orders that prohibited publication that an injunction had been granted (the so-called ‘super-injunction’).   The conflict of interests as between the right to privacy of individuals and freedom of communication of media organisations is discussed in my recent blog on the decision of Mosley v United Kingdom.

Dan Sabbagh, on The Guardian newspaper blog, in considering the potential liability of Twitter and Facebook for content posted by users, refers to the 2009 decision in Metropolitan International Schools v Designtechnica and Google, in which Mr Justice Eady commented that “[o]bviously Google has no control over the search terms entered by users of the search engine or of the material which is placed on the web by its users.”[3]  Dan Sabbagh summarised the conclusion as to the liability of Google as being it “could not be held liable when it came to defamation because it had not published the material that appeared on its website.”[4]  Search engines operate with search algorithms that automatically produce results.  That case can be argued as not providing a close analogy to the situation facing Twitter and Facebook in that social media websites are publishing media rather than technologies that search for information published elsewhere on the web. 

The question is what is the responsibility of the operator of the social media technology for information posted by account holders?  The purpose of a court order directing anonymity of a person is exposed to the risk that a posting on Twitter and Facebook can be automatically posted elsewhere on those sites, with the possibility of the posts being further linked to other sites including blogs.

To the extent that defamation law may provide assistance in determining the liability of social media sites, the common law defence of innocent dissemination suggest that a social media site should be responsible for content posted by account holders, that is until notice is given of the existence of the defamatory material, whereupon a duty to remove the material will exist.[5]
However the enforcement issue remains, Twitter or Facebook may choose to voluntarily comply with court orders made in ‘foreign’ jurisdictions; otherwise those who seek the protection of anonymity orders face the loss of protection of anonymity orders due to the viral spread of the information on social networking sites.


[1] Kevin Rawlinson, Social networking sites consider UK court ruling (13 May 2011) http://www.independent.co.uk/news/media/online/social-networking-sites-consider-uk-court-ruling-2283766.html

[2] Roy Greenslade, Can Twitter gag tweeters without giving the game away? (9 May 2011) http://www.guardian.co.uk/media/greenslade/2011/may/09/medialaw-twitter

[5] Morris Averill, Defamation – The Internet & the World-Wide Web, (Internet Law Anthology) Prospect Publishing (1997).  In the United Kingdom the ‘innocent dissemination’ defence has been “superseded” by s.1 of the Defamation Act 1996 (UK).

Wednesday, 6 April 2011

The diagnosis & treatment of allergies to ACCC legal action over FaceBook posting by ‘fans’ of a company

Allergy Pathway operates clinics for the diagnosis and treatment of allergies.  In 2009 the Australian Competition and Consumer Commission (ACCC), as competition regulator, formed the opinion that the way in which Allergy Pathway promoted its services in traditional media and on the web breached the Trade Practices Act 1974 (Cth) in the following ways: Allergy Pathway engaged in misleading or deceptive conduct (s 52); falsely represent that services are of a particular standard or quality (s 53(aa)); represent that services have benefits they do not have (s 53(c)); and engage in conduct that is liable to mislead the public (s 55A).

Justice Finkelstein in the Federal Court, accepted the claims of the ACCC and ordered Allergy Pathway to carry out corrective advertisement, including on “all websites which are owned, operated, controlled or maintained by or on behalf of” Allergy Pathway;[1] in addition a trade practices compliance training program was ordered to be implemented by the company. The matter should have ended there but for a later social media marketing campaign that included a YouTube video uploaded by the company, which was linked to FaceBook and Twitter posting by Allergy Pathway.

This marketing campaign ended up with the company facing contempt of court proceedings for breach of the 2009 orders.  The outcome was that fines of $7,500 were imposed (the ACCC was asking for $10,000).

The YouTube video, FaceBook posting and Twittering by the company seem an uncomplicated claim, however part of the ACCC’s claim against the company was the posting by ‘fans’ on the Facebook wall and Twitter messages was the responsibility of Allergy Pathway and was part of the company’s contempt of the court orders.

In a February 2011 judgment Finkelstein J. describes the ACCC’s allegation as being that the contempt of the 2009 orders was made up of publications that were grouped into several categories: ‘(1) statements and links to statements posted by Allergy Pathway on its website and Facebook and Twitter pages and in a video posted on YouTube and embedded on its Facebook and Twitter pages; (2) testimonials written by clients and posted by Allergy Pathway on its website and Facebook and Twitter pages; (3) testimonials written and posted by clients on Allergy Pathway’s Facebook “wall”; and (4) Allergy Pathway’s responses to queries posted by members of the public on its Facebook wall.”[2]

Allergy Pathway conceded that most of the statements in categories (1), (2) and (4), breach the 2009 orders. The category (3) statements were the subject of argument before Finkelstein J. as to whether statements posted on the respondent’s Facebook and Twitter pages by others constitutes publication by Allergy Pathway. To restate part of the 2009 orders the company undertook not “make or publish or cause to be made or be published, in any internet website”[3] statements (set out in the judgment) that had been determined to breach the Trade Practices Act.

To determine whether the social media campaign was caught by this 2009 undertaking, Finkelstein J. considered cases from defamation law in order to focus on the meaning of the words “publish” and “make”.  There are pre-internet cases on posting on walls of the golf club premises in England and the walls of lavatories in Texas bars, which put the responsibility on the person in charge of the premises to remove defamatory material, after it has been brought to their attention. I cover these cases in a 1997 article on defamation on the internet.[4]

Since that time there have been a number of internet cases that confirm, with regard to defamation law, that the person in charge of a ‘virtual’ wall has responsibilities to remove defamatory material, after it has been brought to their attention.  Finkelstein J. commented that that Allergy Pathway had conceded that it “knew that persons had published testimonials on its Twitter and Facebook pages and that it took no steps to have them removed. I infer that one reason Allergy Pathway did not remove the testimonials was that it wanted to take the benefit of the praise for its services. Another possible reason is that Allergy Pathway thought the testimonials added legitimacy to its business.”[5] Applying the line of reasoning from the defamation cases Finkelstein J. concluded that Allergy Pathway became the publisher of the testimonials and “accepted responsibility for the publications when it knew of the publications and decided not to remove them”. [6]

The end result of the social networking campaign for the company was that it had to pay the fines, the full legal costs of the ACCC (on an indemnity basis) and carry out further corrective advertising on the front counter of its clinics, its website and Twitter and Facebook pages. Allergy Pathway was also required to send a letter (electronically or otherwise) to all of its customers explaining what has occurred.

What can be taken from this case is that for whatever media is being used – is that first you have to get the message compliant with Federal trade practices legislation[7] and the fair trading legislation of the States or Territories; the second take out from the case is the social media campaign has to be actively managed.

Any virtual ‘wall’ that customers can post to, must be edited to keep it on message and avoid statements that the ACCC or state or territory fair trading departments may jump on.  Not all praise from customers is good news; such as if it acts to mislead other customers or potential customers (in way prohibited by trade practices and fair trading legislation). 

If any messages act to misrepresent the products or services or otherwise are misleading or deceptive messages; then if they remain for a significant time on the virtual ‘walls’ set up as part of any social media campaign, the company responsible for setting up and managing the virtual ‘walls’ will be accepted as taking responsibility for the publishing of the misleading messages – which can have consequences as described above.


[1] ACCC v Allergy Pathway Pty Ltd [2009] FCA 960 (27 August 2009)
[2] ACCC v Allergy Pathway Pty Ltd (No 2) [2011] FCA 74 (10 February 2011) [8].
[3] ACCC v Allergy Pathway Pty Ltd [2009] FCA 960 (underlining added for emphasis).
[4] Morris Averill, ‘Defamation – The Internet & the World-Wide Web’, published in ‘Internet Law Anthology ‘, Prospect Publishing (1997).
[5] ACCC v Allergy Pathway Pty Ltd (No 2) [2011] FCA 74 [32].
[6] Ibid. [33].
[7] The Trade Pactices Act 1974 (Cth) has been superceded by the Competition and Consumer Act 2010 (Cth) but the obligations remain the same.