> The SAC purports to document fluctuations in plaintiffs’ overall star ratings that apparently correlate with their advertising decisions, but it in actuality only provides select snapshots of plaintiffs’ overall star ratings. [...] Chan’s mixture of positive and negative reviews fluctuated over time irrespective of the activities complained of in the SAC, and in the absence of a more complete picture of Chan’s reviews, the court cannot equate a few drops in overall star ratings to an implied threat of harm from Yelp. These fluctuations could just as easily be the result of planted ads by plaintiffs, the functioning of Yelp’s automated filter, or negative attacks from competitors or former employees.
Having completely destroyed the value of their brand Yelp still gets traffic at least until the next briefly honest startup shows up.