Failure to make a prima facie case that an anonymous e-mail was defamatory is grounds to quash a subpoena seeking the message-writer’s identity, the Appellate Division of the Superior Court in New Jersey says.

No plaintiff “is entitled to an order unmasking an anonymous author when the statements in question cannot support a cause of action for defamation,” the court said in A.Z. (a minor) v. Doe, A-5060-08.

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