A plaintiff who fails to make out a claim of intentional infliction of emotional distress based on anonymous, offensive e-mails can’t compel the sender’s Internet service provider to reveal his or her identity, a New Jersey appeals court held Tuesday in a published opinion.

The ruling, in Juzwiak v. Doe, A-2302-09, instructs how e-mails fit into the contours of the decade-old precedent that allowed for unmasking anonymous posters of injurious comments on the Web if certain tests are met.

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