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Eagle v. Morgan, 2013-11-4303 (E.D. Pa. 2013), represents one of the first trials on the issue of who owns social media accounts: the individual employee who first created the account or the employer whose business was promoted using the account? In Eagle a company’s founder sued her former employer for the alleged illegal use of her LinkedIn account. The U.S. District Court for the Eastern District of Pennsylvania held that an employer’s conduct, absent a company social media policy, resulted in the torts of unauthorized use of name, invasion of privacy by misappropriation and misappropriation of publicity. The court, however, held the employer not liable for conversion, tortious interference with contract, civil conspiracy and civil aiding and abetting. Lastly, the court rejected the employer’s counterclaims of misappropriation and unfair competition.

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