Partner Gonzalo Mon authored the E-Commerce Law Reports article "Extortion." The article discusses the United States Court of Appeals for the Ninth Circuit case Levitt v. Yelp! Inc. In this case, four plaintiffs filed a suit alleging that the review site Yelp exerted undue pressure on them, which amounted to extortion, to purchase advertising. The Ninth Circuit determined however that Yelp's business practices are just 'hard bargaining.' Gonzalo provides background on Yelp and the criticism they have faced for the way their reviews are manipulated. He also mentions that this decision does not necessarily mean that Yelp and other websites will continue to get away with similar practices.