A growing problem across the internet are online reviews. They are everywhere. But, online reviews represent a problem because they can be manipulated. Or, worse, for some professionals or small business owners, a person can post false, negative reviews and cause serious harm. One former client posted a false, defamatory review about a lawyer in California. The lawyer, Dawn Hassell sued her former client and Yelp. Ms. Hassell won by default and secured a $557,000 judgment for defamation.  But, Yelp appealed. On appeal, the California appellate court found in favor of the lawyer. It rejected Yelp’s arguments based on Sec. 230 of the Communications Dccency Act, claiming it was not responsible for a third party post. The higher court also remanded the matter back to the trial court to narrow the statements that Yelp must take down from its website. See ABA Bar Journal news report.