Siganporia v. Shreyas

Background

Karl Siganporia filed the action on April 8, 2025, naming fourteen defendants. Nine defendants were later dismissed under Federal Rule of Civil Procedure 4(m) because Siganporia did not serve them within the required time. Siganporia stipulated with four of the five remaining defendants to extend their response deadlines.

The remaining defendant addressed in this order was Visweswara Shreyas. The complaint alleged that Siganporia represented a person in divorce proceedings against Shreyas. It further alleged that Shreyas, a former Google employee who had worked on Google’s search engine and who was then employed by Meta Platforms, Inc., used access to Google’s internal systems to promote a Change.org petition so that it appeared among the Google search results for Siganporia’s name. Siganporia alleged that the petition falsely stated or implied that he improperly appointed a court expert and that Shreyas knew the statements were false and intended to cause emotional distress.

The complaint appeared to assert defamation against Shreyas. Reading it liberally, the court also considered whether Siganporia intended to assert claims for intentional infliction of emotional distress, negligent infliction of emotional distress, and violation of the Computer Fraud and Abuse Act of 1986. Shreyas moved to dismiss and moved for summary judgment. Siganporia did not oppose the motions.

Subject-Matter Jurisdiction

The court granted dismissal under Rule 12(b)(1), which permits dismissal when the court lacks subject-matter jurisdiction—the power to hear the case. Siganporia identified federal-question jurisdiction based on the Immigration and Nationality Act, the Computer Fraud and Abuse Act, and the Fifth Amendment.

The court held that the Fifth Amendment and Immigration and Nationality Act theories were asserted only against defendants who had already been dismissed. Those theories therefore could not provide jurisdiction over the remaining action.

Siganporia also cited the Computer Fraud and Abuse Act in the complaint’s jurisdiction section. The court explained that federal-question jurisdiction generally requires a federal claim to appear on the face of a properly pleaded complaint. Although the Act permits a private civil action for certain computer-related violations, the complaint did not identify which provision Shreyas allegedly violated or plead the elements and supporting facts for such a claim. The complaint mentioned the Act only in the jurisdiction paragraph.

The court therefore concluded that Siganporia had not met his burden to establish subject-matter jurisdiction and dismissed the complaint under Rule 12(b)(1). Because it was not clear that amendment of the Computer Fraud and Abuse Act claim would be futile, the court granted leave to amend that claim.

Failure to State a Claim

The court also addressed Shreyas’s alternative argument under Rule 12(b)(6), which tests whether a complaint adequately states a legally recognized claim. The court described the complaint as poorly pleaded and difficult to understand.

As guidance for any amended complaint, the court stated that the defamation claim, as currently pleaded, would not satisfy Rule 12(b)(6). Under California law, defamation requires a publication that is false, defamatory, unprivileged, and naturally likely to injure or causing special damage. The court found that Siganporia identified a publicly available petition, but did not specifically identify the false statements. Instead, the complaint used general conclusions about a defamatory petition and false accusations. The court noted that the petition did not appear to be protected by a privilege, and that the alleged statements could be defamatory if Siganporia identified the specific falsehoods.

The court also found deficiencies in both emotional-distress theories. Negligent infliction of emotional distress is not an independent tort under California law; it is evaluated under negligence principles requiring a duty, breach, causation, and damages. Siganporia did not plead a duty or breach by Shreyas. For intentional infliction of emotional distress, Siganporia did not identify conduct extreme and outrageous enough to satisfy California law.

Summary Judgment

Because the complaint was dismissed for lack of subject-matter jurisdiction, the court denied Shreyas’s motion for summary judgment without prejudice to a further summary-judgment motion if Siganporia filed a viable amended complaint.

Disposition

The court ordered that the complaint was dismissed with leave to amend. Siganporia could file an amended complaint by August 27, 2025. Failure to meet the deadline or cure the identified deficiencies would result in a final dismissal of the suit. Siganporia could not add parties or claims without the court’s express approval or a stipulation of all parties. The order also stated that the nine original defendants already dismissed, and the claims against them, could not be added back through amendment.