From Lord v. Smith, decided last Friday by Judge Virginia Kendall (N.D. Ill.), reaffirming an earlier decision:
Both Lord and Smith are professional online gamers with millions of followers on streaming platforms and social media. They use the handles Ohmwrecker and H2O Delirious, respectively. Lord alleges that Smith began a defamatory online harassment campaign, accusing him of sexual misconduct with a minor and of releasing revenge porn against a different, adult partner. He also claims that Smith promoted harassment and stalking of Lord among Smith's 4.4 million Twitter followers. He says Smith encouraged his fans to threaten Lord with violence and "repeatedly assisted his fans getting access to [Lord's] home address."
Lord is an Illinois citizen, and Smith is a citizen of North Carolina. Lord brings claims against Smith for portraying him in a false light, defamation, tortious interference with prospective economic advantage, and intentional infliction of emotional distress.
Smith moved to dismiss for lack of personal jurisdiction. He submitted an affidavit affirming that he lives and conducts his business in North Carolina, has never set foot in Illinois, and has directed none of his videos, business, or online posts specifically to residents of Illinois. In response, Lord submitted an affidavit that Smith "directed his fans to my home address in Illinois and encouraged his fans to contact and harass me, even when his fans commented on these posts with threats of violence against me."
