Are social media companies based in the United States subject to European data privacy laws? Two recent judicial decisions – one in France and the other in Germany – arrived at different answers. The Civil Court of Paris held that Twitter, based in California, was obligated under the French Code of Civil Procedure to reveal the identity of its users in France who posted racist tweets. In Germany, on the other hand, an administrative court held that Facebook, also based in California, was not subject to a German law that would have prohibited Facebook from requiring users to register under their real names.