It's an interesting issue: Whether freedom of speech is violated by forcing to reveal identities of people, who wish to remain anonymous conserning commercial reviews posted on an internet site. Of concern is the chilling effect this decision has on speech as it undeniably discourages comments from those, who prefer to maintain anonymity, which the First Amendment recognizes as valid. However, where it is alleged that such comments constitute libel, which allegedly resulted in pecuniary loss, the umbrella of free speech protection is weakened. It is further weakened by the fact that the plaintiff is not a public figure or official and that the speech is commercial, and not political.

I imagine that as this issue arises in other jurisdictions, the competing interests may be weighed differently and that rulings, like Virginia's, which force the release of identities, will be narrowly tailored to achieve the individual result. A body of precedent will develop before any broad pronouncement might be rendered.

In the Virginia case the release of the names is particularly vital as the libel action specifically claims that the libelous business reviews were fictitious. I'm not sure what evidence or allegation was submitted to support the claim, but there is a compelling argument that the plaintiff is unduly prejudiced if the names are released.