The Virginia Supreme Court has ruled, in Yelp, Inc., v. Hadeed Carpet Cleaning, Inc., that a Virginia court cannot enforce a subpoena requiring Yelp to reveal the identities of online users because the court lacked subpoena jurisdiction over non-resident non-parties.  The court found that the information sought by the plaintiffs was accessible by Yelp employees in California, but Virginia law does not provide for the exercise of subpoena power over non-party witnesses located outside the state.  As a result, the plaintiff will need to seek enforcement of the subpoena in a California court pursuant to the Uniform Interstate Depositions and Discovery Act.