Politico reports the ruling "could make it easier" for his libel claims to be upheld.
US District Court Judge Ursula Ungaro ruled that Gubarev is not a public figure. That means that the allegations against him, which the outlet published even though they weren't verified, have fewer legal speech protections than would allegations against a public figure.
The dossier contents are increasingly believed to be false. Last week, the FBI released a two-page summary of the document that was used by since-fired FBI Director James Comey to brief incoming President Donald Trump and outgoing President Barack Obama ahead of Trump's inauguration in January.
The summary claimed that former British spy Christopher Steele compiled the dossier for "private clients," but those clients have since been revealed to be Hillary Clinton's presidential campaign and the Democratic National Committee (DNC).
Investigative reporter Michael Isikoff, who was one of the first in the media to report on the dossier, recently cast doubt on some of the key claims contained within it, including that Trump hired Russian sex workers to urinate on a Moscow hotel bed formerly used by Obama (and that the Russian FSB intelligence agency has tapes of it), and that former attorney for Trump Michael Cohen traveled to Prague to coordinate the campaign's alleged cooperation with the Russian government.
Gubarev, for his part, sued BuzzFeed in February 2017, arguing that his reputation and those of his companies were harmed by the allegations in the dossier that said they had worked on behalf of a Russian spy agency to hack emails of prominent Democrats.
Because the judge ruled that Gubarev is not a public figure, in order for his legal team to prove that BuzzFeed libeled him, they no longer have to show that the media outlet did so with "actual malice." Instead, all Gubarev has to prove is BuzzFeed's negligence.
"While we disagree with this narrow opinion, it pertains only to one defense of our decision to publish the Steele Dossier, and has no bearing on the primary rationale: that the Dossier was the subject of official action by our government, briefed to two consecutive presidents and under active and ongoing investigation by the FBI," BuzzFeed spokesman Matt Mittenthal said.
A trial by jury is expected to begin as soon as next month, although both parties have motioned to resolve the matter beforehand. Judge Ungaro has not yet made a decision on those motions.