Themed Rests., Inc. v. Zagat Survey, LLC
Themed Restaurants, Inc., operating as Lucky Cheng's, sued Zagat Survey, LLC for libel, trade libel, and negligence, challenging a negative review in the 2004 NYC Restaurant Survey. The plaintiff alleged a 35% business drop post-publication, attributing it to the survey's low food rating and critical anonymous consumer comments about the restaurant's theme and offerings. The court considered whether survey-based reviews, utilizing anonymous opinions and numerical ratings, constituted protected opinion or actionable defamation. Ultimately, the court ruled that the review's statements and ratings were subjective opinions, not false statements of fact, and therefore protected by free speech principles. Additionally, the plaintiff failed to meet the pleading specificity requirement for constitutional malice. Consequently, the motion to dismiss was granted.