Nikko D’a Mbrosio v. Meta Platforms Inc .

In the
United States Court of Appeals
For the Seventh Circuit
____________________
No. 25-2231
NIKKO D’A MBROSIO,
Plaintiff-Appellant,
v.
M ETA P LATFORMS I NC ., et al.,
Defendants-Appellees.
____________________
Appeal from the United States District Court for the
Northern District of Illinois, Eastern Division.
No. 1:24-cv-00678 — Sunil R. Harjani, Judge.
____________________
A RGUED F EBRUARY 13, 2026 — DECIDED M AY 15, 2026
____________________
Before BRENNAN , Chief Judge, and HAMILTON and S CUDDER ,
Circuit Judges.
HAMILTON , Circuit Judge. In this appeal, we affirm dismis-
sal of a litany of claims arising from a few social media posts
about the plaintiff’s reportedly obnoxious behavior on dates
and after a breakup. We also order plaintiff and his attorneys
to show cause why they should not face sanctions for frivo-
lously appealing the dismissal of his claims against the author
of some of those posts (a woman he briefly dated) and her

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2 No. 25-2231
parents. Plaintiff failed to offer even colorable grounds for re-
versing the claims against those defendants. Moreover, his at-
torney submitted a brief with fictitious quotations, citations,
and claims that should have been avoided with routine cite-
checking.
I. Factual and Procedural Background
Because we are reviewing a grant of motions to dismiss
under Federal Rule of Civil Procedure 12(b)(6), we recount the
facts as alleged in plaintiff’s Second Amended Complaint and
the attached exhibits. See Thompson v. Illinois Dep’t of
Professional Regulation, 300 F.3d 750, 754 (7th Cir. 2002). “Are
We Dating the Same Guy? | Chicago” (“the Group”) is a
Facebook group with around one hundred thousand
members in which women discuss their experiences dating
Chicago-area men. This case arises from several posts made
in the Group about plaintiff-appellant Nikko D’Ambrosio,
who alleges that defendant Abbigail Rajala, a woman he
briefly dated, and over two dozen unidentified users
published photographs of him, made defamatory statements,
and invaded his privacy.
The complaint is not always clear about the precise timing
and sequence of the relevant posts, but they occurred in No-
vember and December 2023. As described in the complaint
and according to the attached exhibits, they amount to the fol-
lowing. Ms. Rajala wrote about her unpleasant experience
briefly dating D’Ambrosio:
We met organically in Chicago two and a half
months ago. Very clingy [and] very fast.
Flaunted money very awkwardly and kept talk-
ing about how I don’t want to see his bad side,

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No. 25-2231 3
especially when he was on business calls. He
came to see me yesterday, and I explained how
I didn’t really want to stay the night[.] I just
wanted to spend the day together. And this was
his response.
Her next comment was:
After I blocked his number, he texted me on an-
other one. Which is the other text screenshot[.]
The first message Ms. Rajala referred to is not in the com-
plaint, but the second is as follows, with expletives cleaned up
for this opinion:
Speak for yourself you ugly vial [sic] fake
whore. Your ego matches that fake f****** face
where you can’t even smile in pictures because
your teeth are so f*****. The truth hurts b**** and
my message will stay with you forever c***.
The manner in which Ms. Rajala took the screenshot did not
reveal D’Ambrosio’s alternate phone number or any other
identifying information. Despite several opportunities,
D’Ambrosio never disputed that he sent this last message un-
til oral argument in this appeal.
Several users responded to Ms. Rajala’s comments with
messages of support and consolation. At least one unidenti-
fied user asked for information about D’Ambrosio’s employer
for the stated purpose of trying to have him fired, but D’Am-
brosio does not allege that Ms. Rajala or anyone else disclosed
any such information.
Another unidentified user with the screenname “Monica
Tska” responded with a link to a news article about a man

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4 No. 25-2231
charged with sexual assault. The story identified the man as
“Anthony LaMonica.” A preview of the article, which appears
in the exhibit attached to the complaint, shows a mugshot of
a man who does not resemble D’Ambrosio. The comment in-
cludes the link and preview alone, with no other commentary.
Ms. Rajala and some of the unidentified users had posted
photographs of D’Ambrosio, each of which showed him
dressed in ordinary clothing, facing the camera and smiling.1
Once D’Ambrosio became aware of the posts, he de-
manded—of whom, exactly, was unclear to the district court
and remains unclear to us—that they be taken down. The
posts remained up, although Ms. Rajala republished her com-
ments anonymously. D’Ambrosio’s complaint included
sweeping, general allegations of economic, professional, emo-
tional, and reputational harms he has suffered from the posts
and their continued visibility.
D’Ambrosio filed this suit in the Northern District of Illi-
nois. He raised several statutory and common-law claims un-
der Illinois law. The gravamen of the allegations against the
defendants remaining in this case is that Ms. Rajala made
some of the posts about him; that defendants Rodney and
Carol Rajala, Ms. Rajala’s parents, were complicit in their
adult daughter’s online activities because she used their home
1 The district court similarly concluded that the mugshot of the man
did not resemble D’Ambrosio, citing Exhibit C, page 4 of the operative
complaint. Page 1 of that exhibit shows another comment from “Monica
Tska” responding to the same post as the link and describing a negative
personal experience with D’Ambrosio. The comment is cut off on the
right-hand side, but it starts with the words: “He is psycho! I met
him . . . .” We ignore this other comment in addressing the defamation
claim because D’Ambrosio has never specifically raised it.

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No. 25-2231 5
internet connection; that the Group’s administrators, defend-
ants Blake Millbrand and Paola Sanchez, co-owners of de-
fendant Spill the Tea, Inc. (collectively, the “STT defendants”),
encouraged the allegedly tortious conduct of Ms. Rajala and
the other users to promote the Group and to boost engage-
ment for purposes of fundraising; and finally that defendant
Meta Platforms, Inc., which operates Facebook, used its tar-
geted recommendation algorithm to amplify the posts to
drive advertising revenue.
Ms. Rajala, her parents, the STT defendants, and Meta
each filed separate motions under Federal Rule of Civil Pro-
cedure 12(b)(6) to dismiss the Second Amended Complaint
for failure to state a claim. The district court granted the mo-
tions, concluded that any further amendment would be futile,
and dismissed the case with prejudice.
D’Ambrosio appeals. The operative complaint asserts di-
versity jurisdiction under 28 U.S.C. § 1332(a). D’Ambrosio
properly alleged the state citizenship of every named defend-
ant, none of whom are citizens of Illinois (as he is), but he did
not allege the state citizenship of twenty-six other unidenti-
fied defendants, users of the Group he named as Jane Does,
including “Monica Tska.” To ensure complete diversity and
with this court’s leave, he dismissed the appeal as to the Jane
Doe defendants so that their unknown state citizenships no
longer matter. See Rao v. J.P. Morgan Chase Bank, N.A., 153
F.4th 541, 549 (7th Cir. 2025), as amended on reh’g, 2025 WL
2752720; Fed. R. App. P. 42(b)(2). We have appellate jurisdic-
tion under 28 U.S.C. § 1291.

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6 No. 25-2231
II. Standard of Review
“To survive a motion to dismiss under Rule 12(b)(6), a
complaint must ‘state a claim to relief that is plausible on its
face.’” Adams v. City of Indianapolis, 742 F.3d 720, 728 (7th Cir.
2014), quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570
(2007). “A claim has facial plausibility when the plaintiff
pleads factual content that allows the court to draw the rea-
sonable inference that the defendant is liable for the miscon-
duct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). We ac-
cept the complaint’s factual allegations as true, but not
“[t]hreadbare recitals of the elements of a cause of action, sup-
ported by mere conclusory statements.” Adams, 742 F.3d at
728, quoting Iqbal, 556 U.S. at 678. We next work our way
through the claims argued on appeal and then turn to sanc-
tions.
III. Statutory Claims
A. Illinois Right of Publicity Act
This claim runs against all remaining defendants. The Illi-
nois Right of Publicity Act (IRPA) prohibits the “use [of] an
individual’s identity for commercial purposes during the in-
dividual’s lifetime without having obtained previous written
consent from the appropriate person.” 765 ILCS 1075/30(a). A
person’s “identity” includes, among other things, his or her
name, photograph, image, and likeness. 765 ILCS 1075/5. A
“commercial purpose” is “the public use or holding out of an
individual’s identity (i) on or in connection with the offering
for sale or sale of a product, merchandise, goods, or services;
(ii) for purposes of advertising or promoting products,

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No. 25-2231 7
merchandise, goods, or services; or (iii) for the purpose of
fundraising.” Id.2
D’Ambrosio’s IRPA claims fail because he has not suffi-
ciently alleged that any defendant used his likeness for a com-
mercial purpose. This section of D’Ambrosio’s opening brief
mentioned Ms. Rajala only once, to note that her “repost was
algorithmically amplified precisely because it generated reac-
tions, which Meta then packaged for advertisers,” Pl. Br. at 3–
6, and it mentioned her parents not at all. D’Ambrosio made
no attempt to connect any factual allegation about any of the
Rajalas’ conduct to a commercial purpose. He also has not
identified any products, merchandise, goods, or services any
of the Rajalas offered for sale, advertised, or promoted, nor
any fundraising campaigns they personally advanced. The
IRPA claims fails as to each of the Rajalas.
D’Ambrosio fares little better with the other defendants.
First, he argued that Meta “algorithmically amplified inflam-
matory content, including unauthorized posts featuring his
likeness, to maximize user engagement—a core monetization
2 In provisions effective January 1, 2025, after the events alleged in this
case, Illinois amended the IRPA to create a claim for unauthorized public
use of a “digital replica.” 765 ILCS 1075/5, 30(b); 2024 Ill. Laws 7585, 7590.
Notably, the digital replica provision does not require a “commercial pur-
pose” and extends liability not only to a principal violator but also to
“[a]ny person who materially contributes to, induces, or otherwise facili-
tates a violation of [§ 30(b)] by another person after having obtained actual
knowledge that the other person is infringing upon an individual’s
rights,” with an exception for digital service providers that is itself subject
to certain complicated exceptions. See 740 ILCS 1075/30(d)–(e). Contrary
to D’Ambrosio’s assertion at oral argument and notwithstanding ques-
tions of retroactivity, this new provision is irrelevant here because he does
not allege the use of a digital replica.

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8 No. 25-2231
vector for Meta through targeted ad revenue.” Pl. Br. at 4. He
cited no case law recognizing an IRPA claim for merely dis-
playing unrelated advertisements near an individual’s like-
ness.
In Huston v. Hearst Communications, Inc., we wrote that an
IRPA claim requires that the “identity must help sell some-
thing—whether it is that product or a separate product or ser-
vice.” 53 F.4th 1097, 1102 (7th Cir. 2022). Examples of using an
identity to help sell something, we noted, include using a per-
son’s image in a media kit to sell advertising space to adver-
tisers; as a free preview for a subscription background report
service; or as a teaser for a license for a higher-resolution, un-
watermarked version of the same image. See id. at 1100–02,
citing first Trannel v. Prairie Ridge Media, Inc., 987 N.E.2d 923,
930, 2013 IL App (2d) 120725, ¶ 22 (media kit); then Lukis v.
Whitepages Inc., 542 F. Supp. 3d 831, 837–38 (N.D. Ill. 2020)
(free preview of subscription service); and then Brown v.
ACMI Pop Division, 873 N.E.2d 954, 959–64, 375 Ill. App. 3d
276, 283–89 (2007) (teaser for license). By contrast, the defend-
ant in Huston, which sold the names and personal information
of nine million Good Housekeeping subscribers to direct mail-
ing advertisers, lacked a commercial purpose because it never
“held out [the plaintiff’s identity] to aid, effectuate, or propose
a commercial transaction.” Id. at 1101–02, 1104. Still, Huston is
not quite on-point, as there the plaintiff’s identity was itself
the product being sold, and the sale necessarily preceded the
disclosure, a point we considered dispositive. Id. at 1101.
Trannel, on the other hand, is more instructive here. Tran-
nel actually involved two uses of the image of the plaintiff and
her minor daughter, who together won a gardening contest
organized by the defendant, a magazine publisher. 987

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No. 25-2231 9
N.E.2d at 925–26, ¶¶ 3–5. The first use was in the defendant’s
magazine, McHenry County Living, reporting on the winners
of the contest, while the second was on the cover of a media
kit the defendant used to sell advertising space in later edi-
tions of the magazine. Id. at 926–27, ¶¶ 6–7. The Appellate
Court of Illinois held that while the media kit was for a com-
mercial purpose, the magazine itself was not: “Contrary to de-
fendant’s argument, we believe that the two publications of
the subject photograph were for entirely different purposes,
one covered by the Act, one not.” Id. at 931, ¶ 25. The pub-
lisher could not be deemed to have had a commercial purpose
for using the plaintiff’s photograph in the magazine merely
because virtually all of the magazine’s revenue came from ad-
vertisements displayed in the magazine. See id. at 925, 927,
¶¶ 3, 12.3
A free-floating profit motive is not enough. We assume
Meta made money from displaying advertisements to people
who viewed the posts. According to D’Ambrosio, advertising
accounts for more than 98% of Meta’s revenue. But a newspa-
per or magazine that prints a story featuring a photograph of
the subject, as in Trannel, does not act with a “commercial pur-
pose” and thereby open itself to potential liability under the
3 The court in Trannel went on to conclude that the magazine story
was “news,” which the IRPA specifically lists as one of several “non-
commercial purposes.” 987 N.E.2d at 931, ¶ 25; 765 ILCS 1075/35(b)(2). We
do not decide whether the posts alleged in this case were “news,” and we
do not read Trannel to suggest that the publisher would have had a
commercial purpose for using the photograph in the magazine if the story
did not qualify as “news,” which it defined as a “report of a recent event:
new information: fresh tidings.” 987 N.E.2d at 931, ¶ 25. The point is that
the mere display of advertisements next to a person’s identity does not
create a commercial purpose under IRPA.

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10 No. 25-2231
IRPA merely because advertisements unrelated to the story
appear in the same publication. Likewise, Meta did not have
a commercial purpose in terms of the IRPA merely because it
displayed advertisements for products or services unrelated
to the posts on the same page with them.
As to the STT defendants, nothing in the complaint sup-
ports D’Ambrosio’s assertion in his brief that his “identity
and the surrounding controversy were engineered into a
spectacle that drove traffic, galvanized support, and served as
the emotional and narrative hook for soliciting funds.” Pl. Br.
at 5. As D’Ambrosio appears to concede, his image “was not
literally displayed on these fundraising pages,” nor were the
posts linked to or from them. Id. Rather, he points to the
“overall marketing scheme,” drawing on Jordan v. Jewel Food
Stores, Inc., 743 F.3d 509 (7th Cir. 2014).
In Jordan, a basketball star asserted several state and fed-
eral law claims, including the IRPA, against a Chicago-area
grocery chain that ran a full-page advertisement in Sports Il-
lustrated Presents “congratulating” him for his induction into
the Hall of Fame and prominently featuring the store’s logo.
Id. at 512, 518. We rejected the store’s First Amendment de-
fense as to all claims. Looking to the “content and context” of
the advertisement, it had an “implicit but easily inferred,”
“dominant,” “unmistakable commercial function” and was
therefore commercial speech for First Amendment purposes,
even though the advertisement did not itself propose a com-
mercial transaction. Id. at 518, 520. Critically, we expressed no
opinion on the merits of any of the claims, including under
the IRPA. Id. at 522. Indeed, on remand the district court de-
nied Jordan’s motion for summary judgment on the IRPA
claim because “the Seventh Circuit twice made clear it was not

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No. 25-2231 11
saying” that speech qualifying as “commercial speech” for
First Amendment purposes means the speaker has a “com-
mercial purpose” under the IRPA. Jordan v. Jewel Food Stores,
Inc., 83 F. Supp. 3d 761, 769–70 (N.D. Ill. 2015).
Jordan does not support the conclusion that the STT de-
fendants’ solicitation of funds in a manner not directly con-
nected to the posts about D’Ambrosio, merely a few of thou-
sands concerning many other men, could amount to the “pub-
lic use or holding out of” his identity “for the purpose of fund-
raising.” 765 ILCS 1075/5. The case addressed a completely
different issue, and D’Ambrosio’s name and likeness do not
have the marketing value remotely comparable to Michael
Jordan’s.4
B. Civil Liability for Doxing Act
The Doxing Act claim runs against Ms. Rajala and the STT
Defendants, but not against Ms. Rajala’s parents or Meta. Illi-
nois’ Civil Liability for Doxing Act took effect in 2024, and this
court has not addressed it before. The Act allows a plaintiff to
obtain damages, injunctive relief, and attorney fees for “dox-
ing,” defined as follows:
An individual engages in the act of doxing
when that individual intentionally publishes
4 Because D’Ambrosio has not sufficiently alleged any defendant had
a “commercial purpose,” we do not address whether the posts fall into the
IRPA exception for the “use of an individual’s identity in an attempt to
portray, describe, or impersonate that individual in a live performance, a
single and original work of fine art, play, book, article, musical work, film,
radio, television, or other audio, visual, or audio-visual work, provided
that the performance, work, play, book, article, or film does not constitute
in and of itself a commercial advertisement for a product, merchandise,
goods, or services.” 765 ILCS 1075/35(b)(1).

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12 No. 25-2231
another person’s personally identifiable infor-
mation without the consent of the person whose
information is published and:
(1) the information is published with the intent
that it be used to harm or harass the person
whose information is published and with
knowledge or reckless disregard that the person
whose information is published would be rea-
sonably likely to suffer death, bodily injury, or
stalking; and
(2) the publishing of the information:
(i) causes the person whose information is
published to suffer significant economic in-
jury or emotional distress or to fear serious
bodily injury or death of the person or a fam-
ily or household member of the person; or
(ii) causes the person whose information is
published to suffer a substantial life disrup-
tion; and
(3) the person whose information is published
is identifiable from the published personally
identifiable information itself.
740 ILCS 195/10(a), 15(b), 20. We read a Doxing Act claim to
have six elements: (1) intentional publication of personally
identifiable information; (2) the published information iden-
tifies a person without reliance on extrinsic sources; (3) lack of
consent to the publication; (4) intent to harm or harass;
(5) knowledge or reckless disregard of a reasonable likelihood
of death, bodily injury, or stalking to the person whose

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No. 25-2231 13
information is published; and (6) one or more of the listed
harms results.
“Stalking” is defined by reference to the Illinois Criminal
Code (with an additional exception for protected protest ac-
tivity not relevant here), which states:
(a) A person commits stalking when he or she
knowingly engages in a course of conduct di-
rected at a specific person, and he or she knows
or should know that this course of conduct
would cause a reasonable person to:
(1) fear for his or her safety or the safety of a
third person; or
(2) suffer other emotional distress.
. . .
(c) Definitions. For purposes of this Section:
(1) ”Course of conduct” means 2 or more
acts, including but not limited to acts in
which a defendant directly, indirectly, or
through third parties, by any action,
method, device, or means follows, monitors,
observes, surveils, threatens, or communi-
cates to or about, a person, engages in other
non-consensual contact, or interferes with or
damages a person’s property or pet. A
course of conduct may include contact via
electronic communications.
. . .
(3) “Emotional distress” means significant
mental suffering, anxiety or alarm.

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14 No. 25-2231
740 ILCS 195/5; 720 ILCS 5/12-7.3(a) & (c). In two cases pre-
ceding the enactment of the Doxing Act, the Illinois Supreme
Court had struck “communicates to or about” from this stat-
ute as facially overbroad under the First Amendment and in-
terpreted “threatens” to cover only true threats of unlawful
violence. People v. Relerford, 104 N.E.3d 341, 356, 2017 IL
121094, ¶¶ 63, 65; People v. Ashley, 162 N.E.3d 200, 218, 2020 IL
123989, ¶ 73, as modified on denial of reh’g.
The required state of mind for a Doxing Act violation is
“knowledge or reckless disregard that the person whose in-
formation is published would be reasonably likely to suffer
death, bodily injury, or stalking,” where stalking requires two
or more acts in which a person “directly, indirectly, or
through third parties, by any action, method, device, or
means follows, monitors, observes, surveils, [or makes a true
threat of unlawful violence about] . . . a person, engages in
other non-consensual contact, or interferes with or damages a
person’s property or pet.” 740 ILCS 195/5, 10(a); 720 ILCS
5/12-7.3(a), (c); Relerford, 104 N.E.3d at 356, ¶¶ 63, 65; Ashley,
162 N.E.3d at 218, ¶ 73.
D’Ambrosio’s allegations do not meet that high standard.
Because he has engaged in classic “shotgun pleading,” pars-
ing what exactly he alleges as to each particular defendant’s
state of mind is not easy. See SEC v. Winemaster, 529 F. Supp.
3d 880, 906 (N.D. Ill. 2021) (defining shotgun pleading). The
complaint makes and reincorporates into each count several
sweeping allegations about “Defendants” without qualifica-
tion, a category that includes not only Ms. Rajala and the STT
defendants but also Ms. Rajala’s parents, Meta, and, at the
time, all twenty-six Jane Does. Among the undifferentiated al-
legations as to the states of mind of all defendants are “actual

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No. 25-2231 15
knowledge of intellectual property violations” and “encour-
age[ment]” of both those violations and the publication of
“men’s personally identifiable information and potentially
defamatory statements,” as well as acting “for financial gain.”
Specific to the Doxing Act claim, the most relevant allega-
tion as to Ms. Rajala and the STT defendants is:
That the Defendants published said information
with knowledge and/or reckless disregard to
the fact that the publishing of defamatory state-
ments accusing someone of horrific crimes such
as criminal sexual assault alongside personally
identifiable information to an online platform of
over 100,000 individuals would cause Plaintiff
to be reasonably likely or otherwise have rea-
sonable fear that he is likely to suffer significant
injury, including risk of death, bodily injury, or
stalking.
D’Ambrosio alleges even further as to Ms. Rajala that she
acted “with the intent of causing him reputational harm and
putting him in reasonable fear of bodily harm to himself or
his family at the hands of any of the 100,000 unidentified
women involved in the unlawful conduct apparent in the ‘Are
We Dating the Same Guy?’ communities.” (Emphasis added.)
D’Ambrosio makes no effort to explain how someone
could reasonably infer from Ms. Rajala’s alleged conduct that
she intended to put him in reasonable fear of death, bodily
injury, or stalking. Nor does he explain how posting her im-
pressions of D’Ambrosio as a date and a screenshot of a vile
text message he sent her to a Facebook group of women shar-
ing stories about men they have dated accomplishes that

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16 No. 25-2231
purpose. None of the posts attributed to Ms. Rajala contain a
call to action, much less a call to action for the Group’s mem-
bers or anyone else to harm D’Ambrosio or his family.
Nor does D’Ambrosio explain how we could reasonably
infer that, even if Ms. Rajala lacked intent, she nonetheless
knew of or recklessly disregarded a reasonable likelihood of
death, bodily injury, or stalking. We emphasize, once again,
that D’Ambrosio never alleged that he was actually stalked or
subjected to bodily injury, nor that anyone attempted to do
so. D’Ambrosio identified no past incidents of physical harm
or stalking directed against men discussed in the Group. The
Group’s rules prohibit sharing screenshots with other people,
and its administrators warn users about the risks of confront-
ing men they personally know whom they see posted on it.
The allegation that Ms. Rajala made “100,000 unidentified
women” become aware of his conduct does not, without
more, support an inference that she recklessly disregarded a
reasonable likelihood that one of those women would physi-
cally harm D’Ambrosio or stalk him. Recall that the purpose
of this online group was to help women identify men to avoid.
The same holds true for the STT defendants. To be clear,
D’Ambrosio’s allegations reasonably support an inference
that the STT defendants recklessly encourage users to post
sensational content regardless of its potentially tortious na-
ture and that they take measures to prevent the subjects of
such posts from becoming aware of their existence and to as-
sist users in avoiding legal responsibility when they cross the
line. Notwithstanding efforts to prevent information posted
on the Group (and the others nationwide) from leaving the
platform, nothing can really stop allegations of anything from
rudeness to serious felonies from spreading elsewhere, as

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No. 25-2231 17
other courts that have addressed these groups have noted. See
Doe v. Weston & Sampson Engineers, Inc., 743 F. Supp. 3d 751,
758–61, 765 (D.S.C. 2024) (denying anonymity because plain-
tiff posted in an “Are We Dating the Same Guy” group under
her own name about subject matter of the lawsuit); Acosta v.
Vann, No. 614173/2023, 2024 WL 3035174, at *4–7 (N.Y. Sup.
Ct. June 17, 2024) (granting defendant’s anti-SLAPP motion
because her statements in an “Are We Dating the Same Guy”
group took place in a “public forum” despite vetting of pro-
spective users). We find no allegations in this case, however,
from which we could reasonably infer that the STT defend-
ants knew of or recklessly disregarded a risk to D’Ambrosio
of death, bodily injury, or stalking.
Having dispensed with the merits of this claim, we can
now turn to some serious problems with D’Ambrosio’s open-
ing brief. These are not the only problems, but we focus on the
Doxing Act claim because that section seemed to have the
highest density of them.
D’Ambrosio’s attorney Aaron Walner wrote in his opening
brief that Section 10 of the Doxing Act defines the term “per-
sonally identifiable information” to include: “Name, address,
telephone number, email address, social security number, or
any other information that can be used to identify a specific
individual.” Pl. Br. at 14, 20. But the definition comes in Sec-
tion 5, not Section 10, and despite the use of quotation marks,
that’s somewhat close but not quite right.5
5 In the Doxing Act:
“Personally identifiable information” means any infor-
mation that can be used to distinguish or trace a person’s
identity, such as name, prior legal name, alias, mother’s

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18 No. 25-2231
We see such sloppy work in briefs fairly often, and almost
always let it pass without comment as we try to focus on the
merits of appeals. But the next sentence in attorney Walner’s
opening brief for D’Ambrosio said: “First, Illinois courts have
consistently recognized that ‘any other information that can
be used to identify a specific individual’ must be understood
contextually.” Pl. Br. at 14. No citation followed that claim
about what the Illinois courts have actually done. We were not
surprised to find no cases supporting the proposition. In fact,
we found, as of the date of the opening brief, only one Illinois
court decision indexed on Westlaw or Lexis even citing this
statute. To the extent that decision is relevant at all, it seems
to suggest the opposite of what D’Ambrosio asserted. See
Younge v. Berman, 267 N.E.3d 346, 358–59, 2025 IL App (2d)
240354, ¶ 35 (publishing photograph of government official’s
maiden name, and date or place of birth in combination
with any other information that is linked or linkable to a
person such as:
(1) social security number, home address, phone num-
ber, email address, social media accounts, or biometric
data;
(2) medical, financial, education, consumer, or employ-
ment information, data, or records;
(3) any other sensitive or private information that is
linked or linkable to a specific identifiable person, such as
gender identity, sexual orientation, or any sexually inti-
mate visual depiction; or
(4) any information that provides access to a person’s tel-
econferencing, video-teleconferencing, or other digital
meeting room.
740 ILCS 195/5.

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No. 25-2231 19
house did not violate Doxing Act since nothing in photograph
directly suggested the identity of the owner).6
The next paragraph was worse:
Moreover, screen names, location tags, and
group context provide the connective tissue that
transforms partial identifiers into actionable
disclosures. This view is supported by broader
federal data privacy standards, which recognize
[personally identifiable information] to include
“any unique identifier that permits the physical
or online contacting of a specific individual.”
(FTC v. Accusearch Inc., 570 F.3d 1187 (10th Cir.
2009)).
Pl. Br. at 14. The cited Accusearch case is real, but the quotation
is not. Accusearch concerned the disclosure of “individually
identifiable customer proprietary network information” as
that term is used in the federal Telecommunications Act, 47
U.S.C. § 222. 570 F.3d at 1192. The words “unique,” “identi-
fier,” and “contacting” do not appear in the opinion, nor does
the phrase “specific individual.”
In the next paragraph, attorney Walner’s brief for D’Am-
brosio misstated the standard for liability under the Doxing
Act and once again misstated the relevant section as follows:
6 D’Ambrosio’s reply brief, also apparently written by Walner, admit-
ted: “No reported appellate decision has yet construed the statute.” Pl.
Reply Br. 4, 10. We say “apparently” because while Walner signed the cer-
tificates of compliance and service, the brief itself is unsigned. See Fed. R.
App. P. 32(d).

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20 No. 25-2231
1. Publication of [personally identifiable infor-
mation];
2. With the intent to cause or reckless disregard
of the risk of causing: (a) stalking, harassment,
physical harm, or emotional distress.
Pl. Br. at 14. Once again, that’s not the standard. See 740 ILCS
195/10(a)(1). In the following paragraphs, the brief applied
this inaccurate standard and concluded as follows:
This is precisely the type of “amplified exposure
and endangerment” that the Act was designed
to prevent. As the Illinois General Assembly ex-
plained in its legislative findings, the doxing
statute addresses the growing problem of
“cyber vigilantism” that results in victims being
targeted, harassed, and shamed in their real
lives.
Pl. Br. at 15. The brief included no citation to any legislative
findings, let alone any including the statute’s targets as the
brief asserted. We could not find any reference to the phrases
“amplified exposure and endangerment” or “cyber vigilan-
tism” within the Doxing Act. There also are no legislative
findings included in the codification of the Doxing Act, 740
ILCS 195/1 et seq., the session law, 2023 Ill. Laws 8103–07, or
any publicly available version of the bill.
These mistakes and fictitious quotations bear the hall-
marks of the misuse of generative artificial intelligence. See,
e.g., Jones v. Kankakee County Sheriff’s Dep’t, 164 F.4th 967, 969–
70 (7th Cir. 2026) (summarizing potential and problems with
use of generative artificial intelligence in briefing). The web-
site of Trent Law Firm, P.C., where D’Ambrosio’s attorneys

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No. 25-2231 21
both practice, boasts of the firm’s extensive incorporation of
artificial intelligence into all areas of its representation. See
How Marc Trent Uses AI to Deliver Cutting-Edge Legal Solutions,
MarcTrent.ai (Dec. 3, 2025), https://perma.cc/6UHF-ABK2.
Without making any broad judgments about the use of artifi-
cial intelligence for help in drafting briefs, however, regard-
less of how these particular errors came about, “submission
of a brief with numerous fictitious citations and quotations is
a serious dereliction of counsel’s duty to serve as an officer of
the court. ‘Citing nonexistent case law or misrepresenting the
holdings of a case is making a false statement to a court. It
does not matter if [generative AI] told you so.’” Prososki v. Re-
gan, 32 N.W.3d 593, 607, 321 Neb. 38, ___ (2026) (alteration in
original), quoting Maura R. Grossman et al., Is Disclosure and
Certification of the Use of Generative AI Really Necessary, 107 Ju-
dicature 68, 75 (2023), citing in turn Model Rule of Profes-
sional Conduct 3.3 (ABA 1983).
Submitting fictitious quotations to a court, regardless of
how they are generated, is obviously inconsistent with the
standards of conduct this court expects from attorneys prac-
ticing in this court and the standards of appellate briefing im-
posed by Federal Rule of Appellate Procedure 28. See
McCurry v. Kenco Logistics Services, LLC, 942 F.3d 783, 791 (7th
Cir. 2019); see also Dec v. Mullin, 171 F.4th 940, 947–48 (7th
Cir. 2026) (under circuit’s standards of professional conduct,
attorneys promise they will “not knowingly misrepresent,
mischaracterize, misquote, or miscite facts or authorities in
any oral or written communication to the court”).

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22 No. 25-2231
IV. Common-Law Claims
A. Defamation
The defamation claims run against Ms. Rajala, the STT de-
fendants, and Meta. D’Ambrosio’s opening brief focuses on
the comment made by “Monica Tska,” which he claims cre-
ated a “clear” (and false) implication that he is the sex of-
fender discussed in the article. D’Ambrosio does not allege
that Ms. Rajala made this statement or is the same person as
“Monica Tska.” Rather, he seeks to hold the STT defendants
and Meta liable as publishers or re-publishers. Illinois law,
with some wrinkles, imposes liability on authors, publishers,
and re-publishers of actionable defamatory statements. See
Catalano v. Pechous, 419 N.E.2d 350, 361, 83 Ill. 2d 146, 168
(1980) (republisher liability); Kolegas v. Heftel Broadcasting
Corp., 607 N.E.2d 201, 204, 154 Ill. 2d 1, 5–6 (1992) (defamation
suit against radio hosts and broadcasting company); Bryson v.
News America Publications, Inc., 672 N.E.2d 1207, 1212, 174 Ill.
2d 77, 83 (1996) (defamation suit against writer and publisher
of magazine article).7
Under Illinois law, “words that impute the commission of
a criminal offense” are “considered actionable per se and give
rise to a cause of action for defamation without a showing of
special damages.” Bryson, 672 N.E.2d at 1214, 174 Ill. 2d at 88.
However, Illinois applies the innocent construction rule, un-
der which a statement “will not be actionable per se if it is rea-
sonably capable of an innocent construction.” Tuite v. Corbitt,
7 We do not address Section 230 of the Communications Decency Act,
47 U.S.C. § 230, an affirmative defense raised in the alternative by both the
STT defendants and Meta. See G.G. v. Salesforce.com, Inc., 76 F.4th 544, 565–
67 (7th Cir. 2023); Huon v. Denton, 841 F.3d 733, 741–42 (7th Cir. 2016).

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No. 25-2231 23
866 N.E.2d 114, 121, 224 Ill. 2d 490, 502 (2006). The question is
whether, “in context, giving the words, and their implica-
tions, their natural and obvious meaning,” the statement
“may reasonably be innocently interpreted or reasonably be
interpreted as referring to someone other than the plaintiff.”
Bryson, 672 N.E.2d at 1215, 174 Ill. 2d at 90, quoting Chapski v.
Copley Press, 442 N.E.2d 195, 199, 92 Ill. 2d 344, 352 (1982). The
innocent construction rule does not apply to an action for def-
amation per quod, which under Illinois law requires a plaintiff
to plead and later to prove special damages. Tuite, 866 N.E.2d
at 121, 123, 224 Ill. 2d at 501, 504.
On defamation per se, we agree with the district court that
the comment made by “Monica Tska” is reasonably suscepti-
ble to an innocent construction, namely that it refers to some-
one else entirely, one Anthony LaMonica, and does not equate
LaMonica and D’Ambrosio as the same person. Even if a user
did not click the link to read the story, the string of characters
“anthony-lamonica” is clearly visible in the comment itself.
By contrast, D’Ambrosio was identified in the thread as
“Nikko.” Furthermore, appearing immediately below the link
is a teaser of the article which shows a mugshot of a man who
does not resemble D’Ambrosio. (Recall that his likeness was
shared by other users who responded to the post.) In sum, the
names and faces of the two men do not match, “Monica Tska”
did not say they are the same person, and there is no indica-
tion in the complaint or exhibits that any other user re-
sponded to her comment in any way, much less to suggest
such an identification. D’Ambrosio’s last argument is that the
comment must be read to imply he is LaMonica because it was
posted in response to a call for information about himself. See
Tuite, 866 N.E.2d at 127, 224 Ill. 2d at 512 (noting in innocent
construction case that “the context of a statement is critical in

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24 No. 25-2231
determining its meaning”). But the innocent construction is
reasonable, so the defamation per se claim based on this com-
ment must fail.
As for defamation per quod, Illinois law requires pleading
special damages, so in federal court such damages sought
must be “specifically stated.” Fed. R. Civ. P. 9(g); Muzikowski
v. Paramount Pictures Corp., 322 F.3d 918, 927 (7th Cir. 2003).
D’Ambrosio did not “itemize his losses or plead specific dam-
ages of actual financial injury.” Muzikowski, 322 F.3d at 927.
Instead, he alleged in support of his defamation per quod claim
only generally and without elaboration, “emotional distress,
emotional loss, loss of professional opportunities, and dam-
age to his reputation and relationships.” The damages alleged
as to his other claims and incorporated by reference in this
claim were similarly vague, and equally unsupported by fac-
tual allegations. Nowhere did D’Ambrosio “identify a con-
crete loss,” for example, specific professional opportunities
denied to him because of the statements. See Pippen v. NBCU-
niversal Media, LLC, 734 F.3d 610, 614 (7th Cir. 2013); see also
Action Repair, Inc. v. American Broadcasting Cos., 776 F.2d 143,
150 (7th Cir. 1985) (“Although an estimation of final total dol-
lar amounts lost is unnecessary, the pleadings must demon-
strate some actual pecuniary loss.”) (citation omitted). That
omission dooms any defamation per quod claim.
Questioned at oral argument about the basis of any defa-
mation claim against Ms. Rajala, D’Ambrosio’s other attor-
ney, Marc Trent, for the first time disputed the authenticity of
the text message Ms. Rajala attributed to him and asserted it
was “plausible” that she made it up. That message, recall,
calls her an “ugly vial [sic] fake whore,” a “b****,” and a
“c***.” Despite having every incentive and multiple

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No. 25-2231 25
opportunities to do so, D’Ambrosio never disputed the au-
thenticity of the text or its attribution to him before the district
court, nor in his opening or reply briefs on appeal. At oral ar-
gument, attorney Trent could identify no evidentiary basis for
disputing his client sent the message. “Arguments raised for
the first time at oral argument are forfeited.” Marvin v. Hol-
comb, 72 F.4th 828, 833 n.6 (7th Cir. 2023). Every other state-
ment attributed to Ms. Rajala is an opinion protected by Illi-
nois defamation law and the First Amendment. See Law Of-
fices of David Freydin, P.C. v. Chamara, 24 F.4th 1122, 1129 (7th
Cir. 2022). And regardless, D’Ambrosio has never alleged or
argued that anything else she said is false. The defamation
claim fails.8
B. False Light & Civil Conspiracy
The false light and civil conspiracy claims also run against
Ms. Rajala, the STT defendants, and Meta. Illinois recognizes
the common law tort of false light invasion of privacy. Lovgren
v. Citizens First National Bank of Princeton, 534 N.E.2d 987, 989,
126 Ill. 2d 411, 418 (1989). Decisions by Illinois courts and this
court consistently conclude that the innocent construction
rule in Illinois law applies to a false light claim unless the
plaintiff has met the requirement for pleading special dam-
ages. See Muzikowski, 322 F.3d at 927 (“The ‘of and
8 Falsely attributing a text message of that nature does not fall into any
of the categories of defamation per se recognized by Illinois law, but we
assume it could give rise to a plausible claim for defamation per quod. It’s
not hard to understand that being identified as the author of such a text
“is a statement that harms a person’s reputation to the extent it lowers the
person in the eyes of the community or deters the community from asso-
ciating with her or him.” Green v. Rogers, 917 N.E.2d 450, 459, 234 Ill. 2d
478, 491–92 (2009).

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26 No. 25-2231
concerning’ requirement is basically the same as the innocent
construction rule. If the statements can reasonably be con-
strued as referring to somebody other than Muzikowski, then
they are not ‘of and concerning him,’ and cannot state a false
light claim.”) (citation omitted), citing Harte v. Chicago Council
of Lawyers, 581 N.E.2d 275, 280, 220 Ill. App. 3d 255, 263 (1991);
see also Benton v. Little League Baseball, Inc., 181 N.E.3d 902,
934, 2020 IL App (1st) 190549, ¶¶ 87–88; Schaffer v. Zekman, 554
N.E.2d 988, 993 & n.2, 196 Ill. App. 3d 727, 734 & n.2 (1990);
Gracia v. SigmaTron International, Inc., 244 F. Supp. 3d 762, 771
(N.D. Ill. 2017) (dismissing false light claim because defama-
tion claim failed due to reasonable construction), aff’d, 986
F.3d 1058, 1066 (7th Cir. 2021) (“The district court . . . rightly
saw SigmaTron’s SEC disclosures as subject to an innocent
construction.”). The failure of D’Ambrosio’s defamation per se
claim on innocent construction grounds dooms his false light
claim.
A civil conspiracy claim is not an independent tort under
Illinois law, so when “a plaintiff fails to state an independent
cause of action underlying its conspiracy allegations, the
claim for a conspiracy also fails.” Chamara, 24 F.4th at 1133,
quoting Indeck North American Power Fund, L.P. v. Norweb PLC,
735 N.E.2d 649, 662, 316 Ill. App. 3d 416, 432 (2000). D’Ambro-
sio pleaded only the false light claim in support of the civil
conspiracy claim, so the claims fall together.
C. Negligence & Products Liability
The claims for negligence, negligent entrustment, and
strict products liability run against Meta alone. In its motion
to dismiss, Meta argued that D’Ambrosio failed to state a
claim on which relief could be granted because his own
allegations (or lack thereof) foreclosed, as a matter of law, an

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No. 25-2231 27
essential element of each claim. D’Ambrosio did not respond
at all as to products liability. His response on the two
negligence-based claims consisted of only one paragraph that
made sweeping assertions that did not actually address the
elements of the claims Meta argued his own allegations
foreclosed and did not support his assertions with citations to
any authorities whatsoever. The district court held that
D’Ambrosio waived these claims by failing to respond
meaningfully to Meta’s arguments. In the alternative, the
court also ruled for Meta on the merits of each claim.
D’Ambrosio addressed the merits of these claims in his
opening brief—appropriate given the district court’s alterna-
tive holdings—but he did not address the district court’s first
basis for dismissing each claim, its conclusion that he waived
them. Whether or not we agree precisely with the district
court’s waiver analysis, on appeal the appellant bears the bur-
den of advancing reasons for reversal. See Rahn v. Board of
Trustees of Northern Illinois University, 803 F.3d 285, 291 (7th
Cir. 2015); see also Dotson v. Faulkner, 138 F.4th 1029, 1031 (7th
Cir. 2025) (“[W]hen the district court decides a case on a par-
ticular ground, that subject must be addressed in the appel-
lant’s opening brief, if appellant wants it reviewed.”). We
could not reverse dismissal of these claims without rejecting
the district court’s conclusion that they were waived, and
D’Ambrosio missed his chance to argue why we should do so.
We therefore affirm without addressing the merits of these
claims.
V. Sanctions
This is a relatively rare appeal in which sanctions appear
to be appropriate. This court may, in its discretion and upon
notice and a reasonable opportunity to respond, impose

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28 No. 25-2231
sanctions for a frivolous appeal by awarding just damages
and single or double costs to the appellee, which may include
an award of an appellee’s attorney fees “limited to work de-
fending the appeal.” Fed. R. App. P. 38; Quincy Bioscience, LLC
v. Ellishbooks, 967 F.3d 613, 616 (7th Cir. 2020).
“An appeal is frivolous if the appellant’s claims are cur-
sory, totally undeveloped, or reassert a previously rejected
version of the facts. An appeal is also frivolous if it presents
arguments that are so insubstantial that they are guaranteed
to lose.” McCurry, 942 F.3d at 791 (citation omitted); see also
Mars Steel Corp. v. Continental Bank N.A., 880 F.2d 928, 938 (7th
Cir. 1989) (en banc) (“An appeal is ‘frivolous’ when the result
is foreordained by the lack of substance to the appellant’s ar-
guments.”). Sanctions may be imposed “for the part of an ap-
peal that is frivolous even if the presence of a colorable
ground prevents the entire appeal from being adjudged friv-
olous.” Hill v. Norfolk & Western Railway Co., 814 F.2d 1192,
1200 (7th Cir. 1987), as amended. Both the party and his attor-
ney may be sanctioned under Rule 38, and they may be held
jointly and severally liable. See Upchurch v. O’Brien, 111 F.4th
805, 814 (7th Cir. 2024).
Separate from Rule 38, when “a judgment is affirmed by
the Supreme Court or a court of appeals, the court in its dis-
cretion may adjudge to the prevailing party just damages for
his delay, and single or double costs.” 28 U.S.C. § 1912; see
also § 1927 (“Any attorney or other person admitted to con-
duct cases in any court of the United States or any Territory
thereof who so multiplies the proceedings in any case unrea-
sonably and vexatiously may be required by the court to sat-
isfy personally the excess costs, expenses, and attorneys’ fees
reasonably incurred because of such conduct.”).

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No. 25-2231 29
The federal rules allow this court to discipline an attorney
who comes before it:
A court of appeals may discipline an attorney
who practices before it for conduct unbecoming
a member of the bar or for failure to comply
with any court rule. First, however, the court
must afford the attorney reasonable notice, an
opportunity to show cause to the contrary, and,
if requested, a hearing.
Fed. R. App. P. 46(c). Such discipline may include a monetary
fine. See Camacho-Valdez v. Garland, 30 F.4th 675, 680 (7th Cir.
2022). Federal courts also possess the inherent authority to
sanction bad faith conduct, even conduct that also may be
sanctioned under a statute or the federal rules. Chambers v.
NASCO, Inc., 501 U.S. 32, 49–50 (1991).
This appeal was entirely frivolous at least as to each of the
Rajalas. Outside of the statement of the case, the Rajalas were
mentioned only once in D’Ambrosio’s opening brief. Even
that was only a passing reference in a paragraph arguing why
the IRPA claim against Meta should go forward. Pl. Br. at 6.
For the IRPA claim, despite sections addressing the supposed
“commercial purposes” of the STT defendants and Meta,
D’Ambrosio conspicuously did not address the Rajalas, even
though the district court concluded that his allegations as to
them were insufficient. IRPA was the only claim on appeal
against Ms. Rajala’s parents.
For the Doxing Act claim against Ms. Rajala, D’Ambrosio’s
arguments can plausibly be read to apply to her. Yet, as dis-
cussed above, that section of his brief is replete with fictitious

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30 No. 25-2231
quotations and misstatements of law, matter that cannot form
the basis of a non-frivolous appeal. See id. at 13–16.
Finally, D’Ambrosio’s attorney Trent asserted that the ba-
sis for the defamation and false light claims (and therefore
also the civil conspiracy claim) against Ms. Rajala were her
posts and her attribution of the text message to D’Ambrosio.
But D’Ambrosio’s opening brief focused on the comment
made by “Monica Tska,” not any of Ms. Rajala’s own posts,
and in no way addressed the district court’s conclusion that
everything she allegedly said was either a fact not in dispute
or an opinion. Moreover, D’Ambrosio had not alleged or even
suggested he did not send the vile text until oral argument in
this appeal, meaning any potential claim based on that state-
ment was doomed as well.
In short, D’Ambrosio and his attorneys failed to advance
any conceivable reason for this court to reverse the dismissal
of any of his claims against any of the Rajalas. D’Ambrosio
and his attorneys, Walner and Trent, are ORDERED to show
cause why this court should not impose the following sanc-
tions:
• Against D’Ambrosio and attorneys Walner and
Trent, jointly and severally, attorney fees the Ra-
jalas incurred defending this appeal and double
costs, payable to the Rajalas, for frivolously ap-
pealing the dismissal of the claims against them.
Fed. R. App. P. 38; 28 U.S.C. §§ 1912, 1927.
• Against attorney Walner, a fine payable to the
clerk of court for misrepresentations of law in
the section of the opening brief concerning the
Doxing Act claim. Fed. R. App. P. 46(c).

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No. 25-2231 31
• Against attorney Trent, a fine payable to Ms. Ra-
jala for disputing at oral argument without any
evidentiary basis that his client sent the text
message she attributed to him. Fed. R. App. P.
46(c); Chambers, 501 U.S. at 49–50.
We will use the following procedure. No later than Mon-
day, June 1, 2026, the Rajalas (Abbigail, Rodney, and Carol)
may submit a statement of their costs and attorney fees in-
curred in this appeal. No later than Tuesday, June 16, 2026,
D’Ambrosio and attorneys Walner and Trent may file state-
ments as to whether and to what extent the court should im-
pose the sanctions proposed above, and they may make any
objections they might have to fees and costs claimed by the
Rajalas. The attorneys may also request an evidentiary hear-
ing as to individual attorney sanctions. The Rajalas may then
file a reply no later than fifteen days after D’Ambrosio and his
attorneys respond.
VI. Conclusion
For the foregoing reasons, the judgment of the district
court is AFFIRMED. D’Ambrosio, Walner, and Trent are
ORDERED to show cause regarding possible sanctions as set
forth above. Single costs are awarded to Meta and the STT de-
fendants. Fed. R. App. P. 39(a)(2). Costs as to the Rajalas shall
be addressed in a subsequent order after they and plaintiff
have submitted their post-opinion statements. The clerk of
court shall forward a copy of this opinion to the Attorney Reg-
istration and Disciplinary Commission of the Illinois Supreme
Court for any action it deems appropriate. To be clear, how-
ever, regardless of how the Illinois authorities assess and re-
spond to circumstances like these, this court expects members
of our bar to exercise diligence to ensure the accuracy of all

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32 No. 25-2231
factual and legal representations in briefs and other filings.
Briefs and other court submissions that include fictitious quo-
tations—inaccuracies discoverable with elementary profes-
sional care—are unacceptable and unbecoming members of
our bar.

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