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Janson v. LegalZoom.com, Inc.

United States District Court for the Western District of Missouri
802 F. Supp. 2d 1053 (2011)


Facts

Todd Janson and others (plaintiffs) who purchased services from LegalZoom.com, Inc. (defendant), brought suit against LegalZoom for unauthorized practice of law. LegalZoom’s website enabled users to answer a few questions and, based on those answers, the website produced a legal document such as a will or a business-formation document. LegalZoom employees, including nonlawyers, reviewed customers’ answers for completeness, inconsistencies, and spelling and grammatical errors. If there was an issue with the submission, a nonlawyer employee would contact the customer for clarification. Additionally, nonlawyer employees provided customer service to customers. The website did not provide legal advice. LegalZoom asserted that its website merely provided access to software that created legal documents and was akin to a “self-help kit.” LegalZoom argued that the customers filled out the forms themselves. Janson moved for summary judgment.

Rule of Law

Issue

Holding and Reasoning (Laughrey, J.)

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