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Barnes v. Facebook Canada Ltd.

Key Issues:

  • Whether the court has jurisdiction over the dispute.
  • Whether Barnes’ Facebook account was used for commercial purposes, triggering Meta’s forum selection clause.
  • Whether Facebook Canada was a proper defendant.

Facts:

  • Toby Barnes, a resident of Newfoundland and Labrador, had a personal Facebook account hacked on May 14, 2022.
  • His account was suspended, and he was notified it would be deleted by December 13, 2022.
  • Barnes sued Meta and Facebook Canada on December 12, 2022, seeking injunctive relief and damages.
  • Facebook reinstated his account after seven months.
  • Barnes initially claimed his personal account was used for business, including managing client pages. He later amended his claim, removing references to business use.

Court’s Findings:

  • Commercial Use: Evidence, including affidavits and Meta’s records, confirmed Barnes used his personal account for business purposes, making the forum selection clause enforceable.
  • Jurisdiction Clause: Meta’s terms required commercial disputes to be litigated in California.
  • Facebook Canada’s Role: The court found no evidence of a contractual relationship between Barnes and Facebook Canada, making it an improper defendant.

Rulings:

  1. Claim Against Meta: Stayed; must be litigated in California.
  2. Claim Against Facebook Canada: Stayed due to lack of contractual relationship.
  3. Costs: Awarded to defendants under Column 3 of the Schedule of Costs. The exact monetary value of the costs was not specified

Conclusion:

The court enforced Meta’s forum selection clause, ruling it lacked jurisdiction. Barnes must file in California. Facebook Canada was not liable.

Toby Barnes
Law Firm / Organization
Regular Power Clarke Lawyers
Lawyer(s)

Keri-Lynn Power

Facebook Canada Ltd.
Law Firm / Organization
Aird & Berlis LLP
Law Firm / Organization
Not specified
Lawyer(s)

J. Michael Collins

Meta Platforms, Inc.
Law Firm / Organization
Aird & Berlis LLP
Law Firm / Organization
Not specified
Lawyer(s)

J. Michael Collins

Supreme Court of Newfoundland and Labrador
202201G5624
Civil litigation
Not specified/Unspecified
Defendant