Disclosure
MKR v Cloudflare Ltd and others [2026] EWHC 2452 (KB)
The King’s Bench Division allowed the claimant’s claim against the second, third and fourth defendants for Norwich Pharmacal relief, requiring disclosure of information to identify the perpetrator of a campaign involving thousands of internet domains embedding the claimant’s name alongside pornographic content. The court found that the claimant had established, among other things, a good arguable case of harassment contrary to the Protection from Harassment Act 1997 and defamation by implication through juxtaposition of her name with adult content. The court held that the mixed up in condition, possession condition and overall justice condition were all satisfied in respect of the second, third and fourth defendants, who had failed to engage with pre-action or claim correspondence. The court was satisfied that disclosure was necessary and proportionate, that there was a strong public interest in enabling the claimant to vindicate her legal rights, and that any competing anonymity interest of the wrongdoer carried limited weight. The court declined to require a cross-undertaking
