Court Issues Decision in Eagle v. Morgan: Employee Owns LinkedIn Account But Fails To Recover Any Damages Against Former Employer

The ownership of social media accounts in the employment context remains a very hot topic. We’ve previously blogged about the the case of Eagle v. Morgan, Case No. 11-4303, E.D.Pa.. The case went to trial in November 2012, and the court has recently issued its trial order, finding that even though the plaintiff successfully proved three causes of action, she failed to prove damages with reasonable certainty, and thus, was unable to recover against her former employer.

Linda Eagle, the former CEO of a banking education company, sued her former employer Edcomm following her termination from the company. After Eagle’s termination, Edcomm allegedly changed the password for her LinkedIn account, preventing her from accessing it, and then replaced her name and photo with that of Sandy Morgan, Eagle’s replacement. In October 2012, the U.S. District Court for the Eastern District of Pennsylvania granted the defendants’ motion for summary judgment on Eagle’s Computer Fraud and Abuse Act and Lanham Act claims. The court denied summary judgment with respect to the state claims asserted by Eagle and retained jurisdiction over state law claims for invasion of privacy by misappropriation of identity, tortious interference with contract, unauthorized use of name in violation of Pa. C.S. § 8316, misappropriation of publicity, identity theft under Pa. C.S. § 8316, conversion, civil conspiracy, and civil aiding and abetting. A bench trial was held in November 2012.

To read this blog post click here