> From my interpretation, a business must request reviews from all customers, via all methods, for each platform, in order to not be considered ‘manipulating co

> From my interpretation, a business must request reviews from all customers, via all methods, for each platform, in order to not be considered ‘manipulating consumers’ There is definitely room for broader enforcement of this judgement, but I don't think your interpretation is correct, especially the "via all methods, for each platform" part. For this specific case, the practice of selectively sending email addresses for 'Review Express' is explicitly considered fraud under TripAdvisor's terms of service (scroll all the way down https://www.tripadvisor.com/TripAdvisorInsights/w789 https://www.tripadvisor.com/TripAdvisorInsights/w789 and https://www.tripadvisorsupport.com/hc/en-us/articles/200615037-What-is-considered-fraud- https://www.tripadvisorsupport.com/hc/en-us/articles/2006150...), so I imagine this made the court's decision easier.