The plaintiffs brought an action for defamation regarding negative online reviews posted by the defendant on Yelp, Google, and Twitter.
The defendant moved under Rule 21 to strike the claim as it was commenced more than two years after the plaintiffs discovered the posts.
The plaintiffs argued that the continuous availability of the posts on the internet constituted multiple publications, retriggering the limitation period each time they were accessed.
The court rejected this argument, holding that the limitation period begins to run when the internet defamation is first discovered, and struck the statement of claim as statute-barred.