Social media sites are transforming not only the daily lives of consumers, but also how companies interact with consumers. Here at Morrison Foerster, across all of our practice groups, we are seeing complex, cutting-edge legal issues arising out of social media. As with the Internet boom during the mid-to-late 1990s, social media is generating new legal questions at a far faster pace than the law’s ability to provide answers to such questions. In an effort to stay on top of these emerging issues, and to keep our clients and friends informed of new developments, Morrison Foerster publishes this blog devoted to the law and business of social media.<h2>ABOUT MORRISON FOERSTER</h2>Morrison Foerster is a leading global law firm that transforms complexity into advantage for its clients. Our clients include some of the largest financial institutions, banks, consulting and accounting firms, and Fortune 100, technology, and life sciences companies. Highlighting the firm’s commitment to client service, leadership in market-changing deals and impact litigation, and values-based culture, Morrison Foerster has been repeatedly recognized as one of the top 10 firms on The American Lawyer’s A-List. Year after year, the firm receives significant recognition from Chambers and The Legal 500 across their various guides, including Global, USA, Asia‑Pacific, Europe, UK, Latin America, and FinTech Legal. Our lawyers passionately care about delivering legal excellence while living our values. Morrison Foerster has a long-standing commitment to creating a culture that respects and celebrates differences, while providing an inclusive environment. The firm has achieved Mansfield Certification Plus since 2018 as a result of successfully reaching at least 30 percent women, communities of color, and LGBTQ+ lawyer representation in a notable number of current leadership roles and committees. The firm also has a long history of commitment to the community and society through providing pro bono legal services, including litigating for civil rights and civil liberties, improving public education and fostering the wellbeing of children, advocating for veterans, promoting international human rights, enforcing the right to asylum, and safeguarding the environment.

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Aaron is the chair of the firm’s Technology Transactions Group and co-chair of the Interactive + Digital Media Group. He advises clients on a wide range of complex transactions involving intellectual property and technology, including structuring and negotiating strategic licensing, development, collaboration, procurement, and distribution deals.Aaron’s practice focuses on advising both established and emerging companies in a variety of data- and technology-intensive sectors, including software, SaaS, cloud-based technology, digital media (social media, AR/VR, gaming, streaming media, AdTech), AI, healthcare, consumer electronics, e-commerce, other online business models, and mobile applications. He also maintains an active practice counseling companies on branding and marketing, trademark licensing, and content-related transactions, as well as the intellectual property aspects of mergers, acquisitions, asset spin-offs, and private equity investments.He has represented clients such as Autodesk, Meta, OpenAI, Splunk, Konami, Kaiser Permanente, SoftBank, Visa, and Yahoo, among others.Aaron has been recognized by numerous publications for his work on market-defining technology transactions. He is currently ranked by Chambers USA for “Technology Transactions.”Aaron also serves as co-editor of Socially Aware, the firm’s award-winning newsletter and blog devoted to the law and business of social media, and regularly publishes on various IP and technology-related topics. Aaron is also a sought-after speaker on new and emerging areas of law, and is a frequent presenter and panelist at conferences and legal services programs. In addition to his active practice, Aaron regularly provides pro bono assistance to various nonprofit and charitable organizations such as Common Sense Media and the Starlight Children’s Foundation. He is a member of the board of directors of California Lawyers for the Arts.While in law school at the University of California, Berkeley, Boalt Hall School of Law, Aaron served as executive editor of the California Law Review and was elected to the Order of the Coif. Following law school, Aaron served as law clerk to the Honorable William H. Orrick and the Honorable Martin J. Jenkins, both United States District Judges for the Northern District of California.

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Partner

Aaron is the chair of our Technology Transactions Group. He advises clients on a wide range of complex transactions involving intellectual property and technology, including structuring and negotiating strategic licensing, development, collaboration, procurement, and distribution deals. Aaron’s practice focuses on advising both established and emerging companies in a variety of data– and technology–intensive sectors, including software, SaaS, cloud computing, AR/VR, AI, gaming, healthcare, consumer electronics, social media, e–commerce, other online business models, and mobile applications. He also maintains an active practice counseling companies on the intellectual property aspects of mergers, acquisitions, asset spin–offs, and private equity investments.

Aaron P. Rubin

Lawrence Gallick is of counsel in the firm’s Austin office and a member of the Technology Transactions Group.Lawrence focuses his practice on technology transactions and licensing matters. His diverse experience includes advising on SaaS agreements, cross-licensing agreements, research and collaboration agreements, development agreements, and distribution agreements. He counsels a broad range of companies across the software, hardware, life sciences, biotech and FinTech spaces, as well as other entities including universities.He advises clients in connection with general corporate matters including contract negotiations, and leasing and technology placement agreements.Lawrence also serves as co-editor of <a href="https://www.sociallyawareblog.com/" target="_blank">Socially Aware</a>, the firm’s award-winning newsletter and blog devoted to the law and business of social media, and regularly publishes on various IP and technology-related topics.Prior to joining the firm, Lawrence was counsel at another major law firm. Before earning his law degree, Lawrence was a web consultant, project manager, and web developer in Portland, Oregon, where he managed and consulted on projects using industry methodologies and performed custom development and integration of content management systems.Lawrence was named a Super Lawyers “Rising Star” in 2015 and 2018–2022, and is licensed in both California and New York. Lawrence earned his J.D. from the University at Buffalo School of Law, where he was the electronic systems editor for the Buffalo Law Review and awarded the ABA-BNA Award for Excellence in the Study of Intellectual Property Law.

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Lawrence Gallick

Anthony Ramirez is a partner in the Technology Transactions Group in the New York office of Morrison Foerster.Anthony advises clients on general commercial and transactional matters. He regularly advises companies on the IP aspects of their M&A transactions. His clients include technology, digital media and content for television and music, financial services, and communications companies with diverse intellectual property assets and issues.His practice focuses on the legal aspects of developing, licensing, and commercializing technology and intellectual property, as well as negotiating general commercial contracts, including outsourcing transactions, as well as content and data licenses. He regularly assists clients with legal issues relating to licensing and commercialization of digital media and content, digital content that is distributed over the Internet or streamed, mobile applications and social media, as well as the licensing of recorded music for distribution via digital platforms. Anthony is also experienced with issues relating to open-source software, software development, artificial intelligence and machine learning, cloud-based technology, and protection of proprietary information.Anthony has extensive experience working on matters involving disruptive technologies, such as blockchain. He has helped fintech clients with general intellectual property issues in connection with terms of service for online financial products and services.Anthony is an integral part of the outside pro bono legal team for nonprofit organizations based in New York, including advising clients on legal issues regarding entertainment, social media, privacy rights, and the negotiation of outsourcing and service agreements. Anthony received his J.D. from the University of Michigan Law School in 2009. He received his B.S. from Cornell University in 2004.

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Anthony Ramirez is a partner in the Technology Transactions Group in the New York office of Morrison Foerster. He advises clients on general commercial and transactional matters. His clients include technology, media, and communications companies with considerable intellectual property assets. His practice focuses on the legal aspects of licensing and commercializing technology and intellectual property, as well as negotiating general commercial contracts. He also regularly assists clients with legal issues relating to mobile applications and social media.

Anthony M. Ramirez

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Socially Aware is devoted to the law and business of social media, proactively addressing emerging issues and keeping our clients informed of new developments. We cover fields such as artificial intelligence, privacy and data security, Section 230, intellectual property, and much more.

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Lawrence W. Gallick

2024 Recap: Ten Lords A-Leaping!

Social Links: If the Suit Fits

Social Links: Age Verification, X Appeal, and the Great White North

Social Links: Fake Reviews, Real Rulings, and an Epic Fail

Lawrence W. Gallick on Toth v. Everly Well, Inc.

Following a recent U.S. district court’s ruling, foreign companies operating cloud-based services may find themselves subject to federal long-arm jurisdiction under the Federal Rules of Civil Procedure 4(k)(2), even if they have no physical presence in the United States. In reaching its decision, the court noted that the question was ripe for consideration by the court of appeals; thus, it remains to be seen whether the decision will stand if appealed.In Plixer International, Inc. v. Scrutinizer GMHB, the District Court of Maine ruled that, while jurisdiction would not exist under Maine’s long-arm statute, the court had specific personal jurisdiction over a German company under federal long-arm statute. Rule 4(k)(2), the federal long-arm statute, provides that serving a summons or filing a waiver of service establishes personal jurisdiction over a defendant if the defendant is not subject to jurisdiction in any state’s courts of general jurisdiction as long as exercising jurisdiction is consistent with the U.S. Constitution and laws.This litigation started when Plixer International, Inc., a Maine firm, filed a case against the German defendant for a variety of trademark-related claims, including trademark infringement. The German company moved to dismiss the case. The parties agreed that the German company was not subject to general personal jurisdiction. Thus, the court was left to decide whether the German company was subject to specific personal jurisdiction under federal long-arm statute and Maine’s long-arm statute.To answer the question of whether jurisdiction was consistent with the U.S. Constitution as required under Rule 4(k)(2), the court applied the “minimum contacts” test set forth in the U.S. Supreme Court’s decision in <a href="https://supreme.justia.com/cases/federal/us/326/310/case.html" target="_blank" rel="noopener noreferrer">International Shoe v. Washington</a>. The test asks whether the defendant has sufficient contacts with the forum such that maintaining the suit in that forum does not offend “traditional notions of fair play and substantial justice.”Under its analysis of federal long-arm statute, the Plixer court focused on whether the German company purposefully availed itself of the privilege of conducting business in the forum State (here, the United States as a whole). Notably, the German company had no physical presence in the United States, but offered cloud-based services from an interactive website and had some U.S.-based revenue. Notwithstanding these limited contacts, the court was satisfied that the German company had minimum contacts with the United States to be subject to personal jurisdiction.As the First Circuit (the applicable appellate court) has yet to determine whether a foreign company can be subject to specific jurisdiction on the basis of an interactive website or sales from such an interactive website, the district court considered some of the factors weighed in other circuits to determine if a website owner would be subject to personal jurisdiction. Such factors included, for example, whether a defendant uses a website to physically send items into the forum state or whether a defendant can be said to be directly targeting forum state residents.The district court found no evidence that the German company “targeted” the United States in particular. Nonetheless, the court went on to find that there were sufficient factors that the German company “purposefully availed” itself of the United States.In particular, the Plixer court noted, German company operated a “highly interactive website that sold its cloud-based services directly through the website, that it was open to business throughout the world, that it accepted recurrent business from the United States in a substantial amount, and that it did so knowingly.” The court also cited the German company’s trademark application in the United States as another factor showing the company’s “desire to deal with the American market.”While recognizing the concern, the court did not agree that its decision might open up all types of foreign website operators to lawsuits in the United States. The court held that the German company engaged in “sizeable and continuing commerce with United States customers” through its website and should not be surprised by the U.S. litigation. The court reached this conclusion notwithstanding that the German company made only about $196,000 in U.S. sales over the prior three and a half years.While being forced to litigate in the United States imposed a significant burden, the court ultimately concluded that exercising specific jurisdiction over the German company was reasonable after considering all the facts and circumstances.With respect to Maine long-arm statute, the court found that personal jurisdiction did not arise, noting that the German company only had “attenuated contacts” with Maine, that the amount of business from that State was “miniscule.” The company had only two Maine customers.Foreign cloud-based service providers should take note of the Plixer decision. Just because they do not have a physical presence in the United States, or ship any products for sale into the United States, does not necessarily mean they are safe from being hauled into a U.S. court, including being forced to defend themselves in states where they may have few if any customers and that they might not even be able to locate on a map.*                   *                  *For other Socially Aware posts addressing litigation-related issues regarding cloud storage solutions, please see: <a href="https://www.sociallyawareblog.com/2017/11/08/us-v-microsoft/" target="_blank" rel="noopener noreferrer">SCOTUS to Resolve Lower-Court Dispute Over U.S. Warrants Seeking Foreign-Stored User Data</a>; <a href="http://www.sociallyawareblog.com/2017/02/23/google-ordered-foreign-stored-user-data/">Google Ordered to Comply with Warrant for Foreign-Stored User Data</a>; <a href="http://www.sociallyawareblog.com/2017/05/03/court-orders-google-foreign-stored-data/#more-6782">Court Orders Google to Turn Over Foreign-Stored Data</a>; and <a href="http://www.sociallyawareblog.com/2016/10/25/email-outside-us/">Second Circuit: Email Stored Outside the U.S. Might Be Beyond Government’s Reach</a>.

L.W. v. Snap Inc.,  675 F. Supp. 3d 1087 

Wamai v. Industrial Bank of Korea , 2021 WL 3038402 

In re Maxus Energy Corp.

In re Energy Future Holdings Corp.

James Paul McCartney v. Sony/ATV Publishing LLC

NFL Enterprises LLC v. EchoStar Satellite LLC

VOOM HD Holdings LLC v. EchoStar Satellite LLC

Change Healthcare Operations, LLC v WebMD Health Corp. 2017 WL 6610411  

Register.com, Inc. v. Verio, Inc.

Komag, Inc. v. Asahi Glass Co. Ltd.

Asante Techs. Inc. v. PMC–Sierra, Inc.

Biovail Corp. v. S.A.C. Capital Mgmt. 2009 WL 2844404 

Multi–Faceted Investigation of University Grants

Confidential International Arbitrations

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Alex advises on all aspects of complex commercial litigation in federal and state trial and appellate courts and in arbitration. He has represented U.S. and international clients in actions involving 

J. Lawrence

J. Alexander Lawrence

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Foreign Cloud-Based Service Providers May Be Subject to Personal Jurisdiction in the United States

Foreign Cloud-Based Service Providers May Be Subject to Personal Jurisdiction in the United States

Following a recent U.S. district court’s ruling, foreign companies operating cloud-based services may find themselves subject to federal long-arm jurisdiction u

After British police unsuccessfully tried to get the blogging platform WordPress.com to remove offensive and threatening posts, the deputy leader of the UK’s Labour Party <a href="https://www.buzzfeed.com/patricksmith/labour-says-the-government-must-consider-changing-the-law?utm_term=.firxjv85m#.nyy54j9GM" target="_blank" rel="noopener noreferrer">vowed to urge changes</a> that would make the country’s laws less tolerant of online abuse.As bipartisan U.S. <a href="https://www.bloomberg.com/news/articles/2017-10-19/russia-probes-spur-lawmakers-on-election-security-social-media" target="_blank" rel="noopener noreferrer">legislation to prevent the appearance of foreign-entity-funded political ads</a> on social media gains traction, <a href="https://www.reuters.com/article/us-twitter-advertising/twitter-to-label-election-ads-after-u-s-regulatory-threat-idUSKBN1CT2XB" target="_blank" rel="noopener noreferrer">Twitter announced</a> that it will impose a “promoted by political account” label on election ads and allow everyone to see all ads currently running on the platform regardless of whom those ads target. These efforts will not prevent automated accounts known as “bots” from influencing voters or spreading fake news on Twitter, but an op-ed in The Guardian suggests the technology to overcome the bots problem exists.While we’re on the subject of potential solutions for the problems that plague social media, one industry observer <a href="https://cointelegraph.com/news/blockchain-might-lead-the-next-social-media-revolution" target="_blank" rel="noopener noreferrer">suggests that blockchain technology</a>, which records digital events on a public ledger and requires consensus among users, could cure social networks’ fake-news and trolling problems, and prevent brands from purchasing fake followers.Legislation is another way of discouraging undesirable online behavior. In <a href="http://www.reporternews.com/story/news/education/2017/10/07/davids-law-cyberbullying-target-abilene-and-other-schools-year/732596001/" target="_blank" rel="noopener noreferrer">Texas, “David’s Law”</a> now requires school districts to create cyberbullying policies and to investigate bullying reports that involve students but take place off-campus or after school hours. And <a href="http://www.wjhg.com/content/news/Proposed-law-would-make-online-threats-a-felony-453209283.html" target="_blank" rel="noopener noreferrer">legislation that cleared a committee in Tallahassee</a> would make threatening someone on social media in Florida a felony punishable by up to 15 years in prison.Should artificial intelligence be regulated? <a href="https://www.theguardian.com/science/2017/nov/05/computer-says-no-why-making-ais-fair-accountable-and-transparent-is-crucial" target="_blank" rel="noopener noreferrer">Some experts believe that the time is now</a>, on the cusp of the AI revolution.Facebook acquired a <a href="https://techcrunch.com/2017/10/16/facebook-acquires-anonymous-teen-compliment-app-tbh-will-let-it-run/" target="_blank" rel="noopener noreferrer">nine-week-old startup</a> whose app encourages teens to anonymously exchange positive feedback.This piece quoting Socially Aware contributor Julie O’Neill explains how <a href="https://www.sociallyawareblog.com/2017/02/14/rules-for-cross-device-tracking/" target="_blank" rel="noopener noreferrer">cross-device tracking</a> can cause employees to expose their organizations to significant data security risks—especially if the employees use their personal devices to perform work-related tasks.The online marketplace eBay <a href="https://www.cnet.com/news/ebay-authenticate-launches-luxury-handbags-wallets/" target="_blank" rel="noopener noreferrer">launched a service for sellers of certain luxury wallets and handbags</a> that relies on experts to verify the authenticity of the goods being sold, backed by a 200% money-back guarantee.Instagram has become such an integral part of promoting restaurants that the Culinary Institute of America will begin <a href="https://www.nytimes.com/2017/10/02/dining/food-photography-culinary-schools-instagram.html?ribbon-ad-idx=5&rref=dining&module=Ribbon&version=context&region=Header&action=click&contentCollection=Food&pgtype=article" target="_blank" rel="noopener noreferrer">offering electives in food photography and food styling</a>.<a href="https://www.usatoday.com/story/money/columnist/strauss/2017/10/06/entrepreneurs-social-media-stardom-within-reach/735328001/" target="_blank" rel="noopener noreferrer">Tips for becoming a social media influencer </a>from a pair of fashion bloggers who made it big.

Aaron is the chair of the firm’s Technology Transactions Group and co-chair of the Interactive + Digital Media Group. He advises clients on a wide range of complex transactions involving intellectual property and technology, including structuring and negotiating strategic licensing, development, collaboration, procurement, and distribution deals.

Aaron Rubin

Social Links: Potential cures for cyberbullying & other social media ills; cross-device tracking could imperil employers; should AI be regulated?

After British police unsuccessfully tried to get the blogging platform WordPress.com to remove offensive and threatening posts, the deputy leader of the UK’s La

Social Links: Potential cures for cyberbullying & other social media ills; cross-device tracking could imperil employers; should AI be regulated?

The U.S. Supreme Court on Oct. 16, 2017, announced it had <a href="https://www.lexislegalnews.com/mealeys-data-privacy/articles/21241/supreme-court-to-hear-case-on-foreign-application-of-stored-communications-act" target="_blank" rel="noopener noreferrer">granted the government’s petition for certiorari</a> in <a href="https://www.leagle.com/decision/infco20160714063" target="_blank" rel="noopener noreferrer">United States v. Microsoft </a>and will hear a case this Term that could have lasting implications for how technology companies interact with the U.S government and governments overseas. At issue is a consequential Second Circuit decision from last year that held that warrants issued under the <a href="https://www.law.cornell.edu/uscode/text/18/2703" target="_blank" rel="noopener noreferrer">Stored Communications Act</a> (SCA) do not reach emails and other user data stored overseas by a U.S. provider.While no federal appellate court besides the Second Circuit has squarely addressed the issue, multiple district courts outside the Second Circuit have declined to follow the Second Circuit’s reasoning in similar fact patterns involving other technology giants. The result is that U.S. law enforcement has different authority to access foreign-stored user data depending on where in the United States a warrant application is made. Google, for example, has expended significant resources to develop new tools to determine the geographic location of its users’ data so as to be in accord with the Second Circuit’s approach. Yet the company currently <a href="https://arstechnica.com/wp-content/uploads/2017/09/fedsgoogflap.pdf" target="_blank" rel="noopener noreferrer">faces a hearing on sanctions for its alleged willful noncompliance with law enforcement requests in the Ninth Circuit</a> based on a district court ruling that parted ways with the Second Circuit.DOJ has gone to great lengths to challenge the Microsoft ruling since its issuance, including pushing for en banc review and seeking to distinguish it in other federal courts. In its petition for certiorari, DOJ contended that the Second Circuit’s decision puts at risk DOJ’s ability to access information that could be critical to uncovering and prosecuting serious crimes. DOJ further contended that the Second Circuit’s analysis rests on a misreading of the statute because the information sought in the warrant—far from requiring extraterritorial application of the statute—could be accessed by Microsoft’s U.S. employees with the click of a mouse. There is also a concern that the Second Circuit ruling will create incentives for “data localization” regimes in which countries insist that data pertaining to their nationals must be stored locally.To Microsoft and other technology companies, on the other hand, the Second Circuit ruling represented the best reading of the SCA—a 1986 law that did not contemplate the current technology landscape—and afforded a measure of protection against the risk they would find themselves subject to conflicting directives under U.S. law and the law of the country where the data is stored. Microsoft’s victory below was embraced by privacy advocates. Microsoft also opposed certiorari on the grounds that to the extent revisions to the SCA were necessary to enable it to apply extraterritorially, the issue was better left to Congress than the courts.Whatever the Supreme Court decides, the case bears close watching as the Second Circuit ruling continues to have serious implications not just for the government but for the U.S. companies that store data and interact with regulators overseas. The case will likely be argued in early 2018 and decided by the end of June.*                   *                  *For other Socially Aware posts addressing user data and the Stored Communications Act, please see the following: <a href="http://www.sociallyawareblog.com/2017/02/23/google-ordered-foreign-stored-user-data/">Google Ordered to Comply with Warrant for Foreign-Stored User Data</a>; <a href="http://www.sociallyawareblog.com/2017/05/03/court-orders-google-foreign-stored-data/#more-6782" target="_self">Court Orders Google to Turn Over Foreign-Stored Data</a>; <a href="http://www.sociallyawareblog.com/2016/10/25/email-outside-us/">Second Circuit: Email Stored Outside the U.S. Might Be Beyond Government’s Reach</a>; and <a href="http://www.sociallyawareblog.com/2012/07/23/weve-come-for-your-tweets-twitter-to-appeal-denial-of-its-motion-to-quash-district-attorneys-subpoena/">We’ve Come for Your Tweets: Twitter to Appeal Denial of Its Motion To Quash District Attorney’s Subpoena</a>.

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SCOTUS to Resolve Lower-Court Dispute Over U.S. Warrants Seeking Foreign-Stored User Data

SCOTUS to Resolve Lower-Court Dispute Over U.S. Warrants Seeking Foreign-Stored User Data

The U.S. Supreme Court on Oct. 16, 2017, announced it had granted the government’s petition for certiorari in United States v. Microsoft and will hear a case th

Technology-company M&A slowed down significantly over the last year, with <a href="https://media2.mofo.com/v3/assets/blt5775cc69c999c255/blt353fe2cd2a7a4dd9/62730eb50cffdf1eb1369b98/1710-451-manda-leaders-survey.pdf" target="_blank" rel="noopener noreferrer">deal volume down by 15%</a> across the globe in Q3 of 2017 compared to Q3 of 2016, and a $37 billion decline to $119 billion in Q3 2017 tech-company deal value compared to the same quarter in 2016.“Outbidding by private equity acquirers” was the primary cause of the plunge, according to almost half (48%) of the industry decision makers who responded to the <a href="https://www.mofo.com/special-content/spotlight-ma-and-leaders-survey/" target="_blank" rel="noopener noreferrer">Tech M&A Leaders’ Survey</a> from 451 Research and Morrison & Foerster. Indeed, 2017 was the first year in history that private equity firms announced more technology mergers and acquisitions than companies listed on U.S. exchanges.In line with these trends have been the companies that fall within the tech industry’s social media subsection—defined by a spokesperson from Index, the source of the data cited here, as “companies that actually own and operate social media platforms, companies that provide services surrounding social media platforms (such as analytics and marketing automation), or companies that operate through social media.”Thus far in 2017, social media companies have been involved in only 58 deals. That slowdown comes on the heels of the biggest year for social-media-company M&A yet, 2016, when there were 136 deals averaging $1.6 billion in value. The biggest of those deals, Microsoft’s acquisition of LinkedIn for $26.2 billion, was also the third-biggest tech-company acquisition in 2016.Struck after LinkedIn’s trading price had <a href="https://www.forbes.com/sites/quora/2016/06/20/5-questions-about-the-linkedin-microsoft-deal-answered/#1348c2ab1e97" target="_blank" rel="noopener noreferrer">dropped</a> to just <a href="https://www.forbes.com/sites/quora/2016/06/20/5-questions-about-the-linkedin-microsoft-deal-answered/#12942e21e97a" target="_blank" rel="noopener noreferrer">a bit more than half of its $250-per-share high on the market</a>, Microsoft’s acquisition of the career-networking site might “prove to be a harbinger of what’s to come for many of those social media companies that did end up going public,” wrote Mashable’s Seth Fiegerman, observing that “many of the flashy social networks that Wall Street once fawned over—even if it didn’t understand what exactly they do—are now looking for the exit door as the mood sours.”Other industry observers <a href="http://www.investors.com/news/technology/click/bold-tech-ma-predictions-for-2017-netflix-twitter-gopro-in-play/" target="_blank" rel="noopener noreferrer">also predicted the acquisition of Twitter</a>, as well as <a href="http://www.businessinsider.com/google-offered-to-buy-snapchat-for-at-least-30-in-early-2016-insiders-say-2017-8" target="_blank" rel="noopener noreferrer">Snapchat</a> and <a href="http://www.businessinsider.com/6-tech-companies-most-likely-to-be-acquired-morgan-stanley-2016-9/#1-take-two-interactive-software-1" target="_blank" rel="noopener noreferrer">Yelp</a>. With all three of those big names yet to be purchased, those predictions obviously didn’t pan out.

Pace of M&A Deals in Social Media Industry Slows After Record Year