Resolute Forest Products, Inc. v. Greenpeace International

The federal district court for the Southern District of Georgia transferred forest-products companies’ lawsuit alleging federal and state Racketeer Influenced and Corrupt Organizations Act (RICO) claims against Greenpeace International and other organizations (Greenpeace) to the Northern District of California. The forest-products companies asserted that the defendants illegally attacked their forestry practices, including by suggesting that the companies created climate change risks by harvesting the Boreal forest. The Georgia federal court found that the companies’ alleged loss of Georgia customers had not occurred in its district and that a trip by the defendants to the district did not give rise to the plaintiffs’ claims. Because two Greenpeace employees who were integral to the plaintiffs’ forestry campaign were based in San Francisco, the court concluded that that a substantial part of events giving rise to the plaintiffs’ claims occurred in the Northern District of California and that venue was therefore proper there.

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A company in the forest products industry and six of its subsidiaries sued Greenpeace, another environmental organization, and a number of individual employees of the organizations under the Racketeer Influenced and Corruption Organizations (RICO) Act in the federal district court for the Southern District of Georgia. The plaintiffs alleged that Greenpeace and the other defendants mounted a campaign identifying the forest products company as a “Forest Destroyer.” The complaint’s allegations included that the defendants told a “whopping lie” by suggesting that the plaintiffs created climate change risks by harvesting the Boreal forest. The plaintiffs claimed that the defendants created and disseminated false and misleading reports and information concerning the plaintiffs, “under the guise of protecting the environment, but in truth, for the unlawful purpose of soliciting fraudulent donations from the public at-large.” In addition to RICO claims, the plaintiffs asserted claims for defamation, tortious interference with prospective business relations, tortious interference with contractual relations, common law civil conspiracy, and trademark dilution.