In contrast, where statements are likely to be taken seriously, Awtry asserts, the balancing in Highfields tends to favor disclosure. Id. (citing Fodor v. Doe, No. 3:10-CV-0798-RCJ VPC, 2011 WL 1629572, at *1 (D. Nev. Apr. 27, 2011)). Finally, Awtry contends the Motion should be granted because his request is "specific and narrowly tailored" in that he is seeking identifying information for only four posts out of the more than 8 million reviews Glassdoor has compiled.

"The court must weigh the rights of the harmed party to expose an anonymous online speaker against the anonymous speaker's First Amendment right of free speech." Fodor v. Doe, Case No. 3:10-cv-798-RCJ-VPC, 2011 WL WL 1629572 at* 3 (D. Nev. April 27, 2011). "There are four different standards court use in online defamation cases: (1) the motion to dismiss or the good faith standard; (2) the prima facie standard; (3) somewhere between the good faith and prima facie standards; (4) the summary judgment standard." Id. (citations omitted).