// Netherlands · Review removal
Patent Office Official Loses Bid to Force Google to Remove Critical Review
Rechtbank Zeeland-West-Brabant ·
ECLI:NL:RBZWB:2020:6923
The case
Patent office Griebling demanded that Google Ireland remove a negative review and provide identification details of the reviewer, claiming the review was fake because they didn't recognize the name. The court denied all claims because the review was professionally worded, not manifestly unlawful, and Griebling had insufficiently proven the review was fake or revenge-motivated.
What the court considered
- 01The review was professionally worded and not unnecessarily offensive or defamatory, making the text itself not unlawful
- 02Griebling failed to sufficiently demonstrate that the review was fake - merely not recognizing the reviewer's name did not make the review unlawful
- 03The review was not 'manifestly unlawful' as required under Article 6:196c paragraph 4 BW, so Google was not obligated to remove it
- 04Griebling had not responded to the negative review herself and thus failed to apply due process (hearing and counter-hearing)
- 05There was no substantiation for claims that it was a revenge action or that there was justified fear of repetition
What this means in practice
Entrepreneurs must have very strong evidence that a review is actually false before judges will proceed with removal. It is advisable to respond to negative reviews yourself and actively manage reputation rather than immediately taking legal action. This ruling confirms the high threshold for removal of online reviews and identification of anonymous reviewers, where freedom of expression carries significant weight against entrepreneurial interests in business-related criticism.
Legal basis
- Artikel 6:196c lid 4 BW
- Artikel 6:196c lid 5 BW
- Artikel 6:162 BW
- Lycos/Pessers criteria voor identificatievorderingen
Related rulings
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- Debt collector loses bid to remove negative Google reviews over opinion statementsNetherlands · 31 October 2025
- Law firm's bid to remove negative Google reviews rejected by courtNetherlands · 15 September 2025
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