Court Rejects Lawsuit Over Online Criticisms of a Dater–D’Ambrosio v. Meta

Abbigail Rajala posted a critical review of her dating experience with Nikko D’Ambrosio on the Chicago subboard of Facebook’s Spill the Tea group. According to the district court, D’Ambrosio “sued anyone remotely associated with those posts for all possible, imaginable claims, including the woman who dated him and her parents, women commenting on posts, the operators of the Facebook group, and Facebook itself.” The district court dismissed his case. The Seventh Circuit affirms, says parts of the appeal may be sanctionably “frivolous,” and calls out the plaintiff lawyers’ misuse of Generative AI.

Illinois Right of Publicity Act

“D’Ambrosio’s IRPA claims fail because he has not sufficiently alleged that any defendant used his likeness for a commercial purpose.”

With respect to Facebook:

A free-floating profit motive is not enough…Meta did not have a commercial purpose in terms of the IRPA merely because it displayed advertisements for products or services unrelated to the posts on the same page with them.

Doxing Act

This is the Seventh Circuit’s first review of Illinois’ recently enacted Doxing Act. It says there are six elements to the claim:

(1) intentional publication of personally identifiable information; (2) the published information identifies a person without reliance on extrinsic sources; (3) lack of consent to the publication; (4) intent to harm or harass; (5) knowledge or reckless disregard of a reasonable likelihood of death, bodily injury, or stalking to the person whose information is published; and (6) one or more of the listed harms results.

The panel says D’Ambrosio didn’t sufficiently allege Rajala’s scienter about placing him in reasonable fear of death, bodily injury, or stalking:

D’Ambrosio never alleged that he was actually stalked or subjected to bodily injury, nor that anyone attempted to do so. D’Ambrosio identified no past incidents of physical harm or stalking directed against men discussed in the Group. The Group’s rules prohibit sharing screenshots with other people, and its administrators warn users about the risks of confronting men they personally know whom they see posted on it. The allegation that Ms. Rajala made “100,000 unidentified women” become aware of his conduct does not, without more, support an inference that she recklessly disregarded a reasonable likelihood that one of those women would physically harm D’Ambrosio or stalk him. Recall that the purpose of this online group was to help women identify men to avoid.

With respect to the Spill the Tea group operators:

D’Ambrosio’s allegations reasonably support an inference that the STT defendants recklessly encourage users to post sensational content regardless of its potentially tortious nature and that they take measures to prevent the subjects of such posts from becoming aware of their existence and to assist users in avoiding legal responsibility when they cross the line. Notwithstanding efforts to prevent information posted on the Group (and the others nationwide) from leaving the platform, nothing can really stop allegations of anything from rudeness to serious felonies from spreading elsewhere…We find no allegations in this case, however, from which we could reasonably infer that the STT defendants knew of or recklessly disregarded a risk to D’Ambrosio of death, bodily injury, or stalking.

The panel has several (unfair IMO) criticisms fordater accountability boards like Spill the Tea. I wonder if those criticisms could be correlated with the fact that all three judges on the panel were old white men who never navigated the dating world as millennial women? 🤔

Though the court rejects this doxing claim, I continue to be extremely nervous about the chilling effects of anti-doxxing statutes. A “reckless disregard” standard gives plaintiffs a lot of room to manufacture controversy out of standard online chatter. Given that thin-skinned individuals–even the US government–take unjustified views of what constitutes doxxing, anti-doxxing statutes are well-positioned to become SLAPP factories.

Defamation

The allegedly defamatory post referenced someone else, not D’Ambrosio, and there was no reason for anyone to believe the post equated the two people. D’Ambrosio also doesn’t make a sufficient showing of reputational damage. As a result, the court says it doesn’t need to address Section 230 because the claim fails for lack of merit. Sidestepping Section 230 is probably for the best in light of the Seventh Circuit’s penchant for overcomplicating its Section 230 analysis.

Sanctions

The panel says “This is a relatively rare appeal in which sanctions appear to be appropriate [because] This appeal was entirely frivolous at least as to each of the Rajalas.” D’Ambrosio sued Rajala’s parents. “Outside of the statement of the case, the Rajalas were mentioned only once in D’Ambrosio’s opening brief.” As for Rajala, the doxxing claim “is replete with fictitious quotations and misstatements of law, matter that cannot form the basis of a non-frivolous appeal.” (More on the hallucinations in a moment). The defamation and false light claims are also unsupportable. The court orders the plaintiff’s lawyers to show cause regarding sanctions.

Misuse of Generative AI 😵🤖

The court says the plaintiffs’ filings, made by lawyers from Trent Law Firm PC, “bear the hallmarks of the misuse of generative artificial intelligence.” The court even notes the firm’s website “boasts of the firm’s extensive incorporation of artificial intelligence into all areas of its representation.” The court refers the matter (plus the frivolous claims) over the Illinois State Bar, but it doesn’t independently sanction any Generative AI misuse. Instead, it makes a short but grandiose statement against Generative AI misuse.

As I’ve mentioned before, I’m increasingly seeing Generative AI misuse in cases where the lawyers display other violations of attorney professionalism, such as the frivolous claims in this case. Maybe the court decided to address the frivolous claims (which appeals courts routinely overlook, at least in terms of sanctions) more aggressively as a backdoor way of redressing their concerns about the Generative AI misuse.

Parting Thoughts

Nikko D’Ambrosio is a multi-time loser: he didn’t seem to be a very good boyfriend, he’s not a good citizen (he committed tax violations), and he’s not a good plaintiff. On the plus side, he did find one perfect match: he found lawyers just as dedicated as he was to Streisand Effect-ing their way to, um, stardom.

Case Citation: D’Ambrosio v. Meta Platforms, Inc., 2026 WL 1361951 (7th Cir. May 15, 2026).

If you have the stomach for it, try to read Trent’s “David v. Goliath” blog post from 2025 about this case. The post has zingers like: “We have a great team—project managers, everything related to AI now. Even Meta can’t beat us.” In retrospect, about that…