"[1] In 2004, an anonymous internet user, referred to in the decision as Doe, posted comments under the alias "Proud Citizen" on a website called the "Smyrna/Clayton Issues Blog" regarding the performance of Patrick and Julia Cahill as City Councilman of Smyrna.

The court rejected the good faith standard due to the danger of bringing suit simply to reveal identity without any intention of pursuing the defamation action to a final decision.

[5] In Dendrite, the court held that a summary judgement standard "is the appropriate test by which to strike the balance between a defamation plaintiff’s right to protect his reputation and a defendant’s right to exercise free speech anonymously.

In the internet context, the plaintiff’s efforts should include posting a message of notification of the discovery request to the anonymous defendant on the same message board as the original allegedly defamatory posting; (2) to set forth the exact statements purportedly made by the anonymous poster that the plaintiff alleges constitute defamatory speech; and (3) to satisfy the prima facie or “summary judgment standard.” Finally, after the trial court concluded that the plaintiff has presented a prima facie cause of action, the Dendrite test requires the trial court to: (4) balance the defendant’s First Amendment right of anonymous free speech against the strength of the prima facie case presented and the necessity for the disclosure of the anonymous defendant’s identity in determining whether to allow the plaintiff to properly proceed.

The precedent was notably applied in Mobilisa, Inc. v. Doe in 2007[6] and still serves as the standard for anonymous internet speech and defamation "in the context of a case involving political criticism of a public figure.