Trade Libel Lawsuit Arising from Statements Made on a Website Disparaging Products

In Renaissance Health Publ'g, LLC v. Resveratrol Partners, LLC, 982 So. 2d 739 (Fla. 4th DCA 2008), a Florida corporation sued the nonresident defendants for trade libel and two related statutory violations, all arising from statements made on the defendants' website allegedly disparaging the plaintiff corporation's products. Id. at 740. The complaint alleged that the defendant sold publications about food supplements (both in a traditional paper format and as e-books) and falsely and intentionally disparaged the quality of the plaintiff corporation's product (a red wine extract). Id. at 742. The court held that the statements on the website constituted a tortious act committed in Florida, reasoning that "the defendants' interactive web site which sells product to Florida residents is akin to the chat room in Becker." Id. The court held that the plaintiff had alleged sufficient facts to satisfy the Florida long-arm statute. Id.