Motise v. America Online, Inc.
Michael V. Motise initiated this action against America Online, Inc. in March 2004, alleging unlawful disclosure of his screen name. America Online moved to dismiss or transfer the case, citing a forum selection clause in its Member Agreement mandating disputes be heard in Virginia. The court examined whether Motise, as a user accessing his step-father's account, was bound by the clause despite lacking direct notice. The court affirmed the enforceability of the forum selection clause through a 'derivative rights theory,' establishing that Motise's access was contingent on his step-father's acceptance of the terms. Consequently, the case was ordered to be transferred to the United States District Court for the Eastern District of Virginia.