Case 2:21-cv-00031-BJR Document 34 Filed 01/21/21 Page 2 of 14 1 2 interference with business expectancy. AWS disputes all three claims, asserting that it is Parler, not AWS, that has violated the terms of the parties’ Agreement, and in particular AWS’s 3 Acceptable Use Policy, which prohibits the “illegal, harmful, or offensive” use of AWS services. 4 It is important to note what this case is not about. Parler is not asserting a violation of any 5 First Amendment rights, which exist only against a governmental entity, and not against a private 6 company like AWS. And indeed, Parler has not disputed that at least some of the abusive and 7 violent posts that gave rise to the issues in this case violate AWS’s Acceptable Use Policy. This 8 9 motion also does not ask the Court to make a final ruling on the merits of Parler’s claims. As a 10 motion for a preliminary injunction, before any discovery has been conducted, Parler seeks only 11 to have the Court determine the likelihood that Parler will ultimately prevail on its claims, and to 12 order AWS to restore service to Parler pending a full and fair litigation of the issues raised in the 13 Complaint. Having reviewed the briefs filed in support of and opposition to the motion, and 14 having heard oral argument by videoconference, the Court finds and rules as follows. 15 II. BACKGROUND 16 17 Parler was founded in 2018, and describes itself as “a conservative microblogging 18 alternative and competitor to Twitter.” Compl., ¶ 1. Parler—like Twitter, Facebook, and other 19 social media entities referenced in this action—is an online platform that allows third-party 20 users, sometimes anonymously, to express thoughts and ideas for other users to read and 21 22 comment on. Parler takes a laissez faire or “reactive” approach to moderation of its users’ speech. See, e.g., Parler’s December 4, 2020 Community Guidelines, Decl. of Ambika Doran, 23 24 25 Ex. B (“We prefer that removing community members or member-provided content be kept to the absolute minimum.”). At the time of the filing of its Complaint, Parler claims to have had 15 million end-user accounts and a million downloads of its app per day. Decl. of John Matze, ¶ 3. 2

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