Johnson v. Meta Platforms, Inc.
- Beth Freeman
- 5:22-cv-05691
- U.S. District Court · Northern District of California
- 7
In Johnson v. Meta Platforms, Judge Bennett denied dismissal but granted transfer to California under Instagram’s forum-selection clause without deciding the merits.
Tiara N. Johnson’s claims against Meta Platforms, Inc. were transferred from the District of Maryland to the Northern District of California; the court deferred arbitration questions to the receiving court.
What happened
In Tiara N. Johnson v. Meta Platforms, Inc. and John Doe, Johnson alleged that Instagram disabled her account, disrupting her business, and that false accounts violated her trademark. Meta asked the court to dismiss the case or transfer it.
The court found that Instagram’s Terms of Use required litigation in the U.S. District Court for the Northern District of California when a dispute was litigated. Johnson could pursue her intellectual-property dispute in court rather than arbitration, but she did not show that the forum-selection clause was invalid or that extraordinary circumstances justified keeping the case in Maryland.
The court denied Meta’s motion as to dismissal and granted it as to transfer, sending the case to the Northern District of California and leaving arbitration questions for that court. Judge Richard D. Bennett also ordered the Maryland case closed.
The detailed version
- Johnson v. Meta Platforms, Inc. · No. 5:22-cv-05691
- Beth Freeman
- Oct. 3, 2022
Background
Tiara N. Johnson alleged that Meta disabled her Instagram account on or about July 1, 2021. She claimed the account had more than 2.8 million followers and supported her business selling adult toys and products. She also alleged that a person identified as John Doe demanded a $3,000 ransom to reactivate the account, and that false or imitation accounts later violated her trademark.
Johnson’s amended complaint asserted claims against Meta for breach of contract, tortious interference with prospective relations, trademark infringement under the Lanham Act, and unfair competition. A separate tortious-interference-with-contractual-relations claim was asserted against John Doe. Meta moved to dismiss under Federal Rules of Civil Procedure 12(b)(2) and 12(b)(6), arguing that the Maryland court lacked personal jurisdiction and that Johnson had not stated a claim. In the alternative, Meta sought transfer to the Northern District of California under Instagram’s Terms of Use.
Forum-Selection Clause
The court explained that a forum-selection clause is a contract term identifying where disputes must be litigated. Instagram’s Terms of Use allowed users to decline arbitration and proceed in court when a dispute related to intellectual property, including trademarks. But the Terms also stated that litigation would be resolved exclusively in the U.S. District Court for the Northern District of California.
The court treated the forum-selection clause as presumptively valid. Johnson did not identify a reason the clause was invalid and did not show extraordinary circumstances that would justify refusing transfer. The court therefore concluded that transfer was the appropriate remedy under 28 U.S.C. § 1404(a).
Arbitration and Disposition
Johnson asked the court to stay the case and compel arbitration. The court deferred those questions to the Northern District of California, explaining that whether arbitration should be compelled is a matter of state contract law. The court also declined to address Meta’s dismissal arguments because it was transferring the case.
The court ordered that Meta’s Motion to Dismiss or, in the Alternative, to Transfer Venue be DENIED as to dismissal, but GRANTED as to transfer. It transferred the matter to the Northern District of California and ordered the Maryland case closed. The order did not decide the merits of Johnson’s claims.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.