How does the First Amendment apply to Yelp reviewers? Is Congress making laws that abridge the rights of free speech in Yelp reviews?
On a separate point, I think the percentage of customers a corrupt business owner could defraud is pretty low. Happy customers may post reviews, but defrauded customers will go after a business like angry hornets. A small number of frauds will become a disproportionate number of negative reviews.
With the comment deleted above, it is difficult to place the context of yours. However, the following is probably relevant/insightful either way:
Judge William Petty wrote that the negative reviews in question were not protected by the First Amendment because "If the reviewer was never a customer of the business, then the review is not an opinion; instead, the review is based on a false statement of fact ... And 'there is no constitutional value in false statements of fact.'"