Section 230 of the Communications Decency Act

Section 230 of the Communications Decency Act (CDA) of 1996 (a common name for Title V of the Telecommunications Act of 1996) is a landmark piece of Internet legislation in the United States, codified at 47 U.S.C. § 230. Section 230(c)(1) provides immunity from liability for providers and users of an “interactive computer service” who publish information provided by third-party users:

No provider or user of an interactive computer service shall be treated as the publisher or speaker of any information provided by another information content provider.

Section 230 was developed in response to a pair of lawsuits against Internet service providers in the early 1990s that had different interpretations of whether the services providers should be treated as publishers or distributors of content created by its users. It was also pushed by the tech industry and other experts that language in the proposed CDA making providers responsible for indecent content posted by users that could extend to other types of questionable free speech. After passage of the Telecommunications Act, the CDA was challenged in courts and ruled by the Supreme Court in Reno v. American Civil Liberties Union (1997) to be partially unconstitutional, leaving the Section 230 provisions in place. Since then, several legal challenges have validated the constitutionality of Section 230. Section 230 protects are not limitless, requiring providers to remove criminal material such as copyright infringement; more recently, Section 230 was amended by the Stop Enabling Sex Traffickers Act in 2018 to require the removal of material violating federal and state sex trafficking laws.

Passed at a time where Internet use was just starting to take off, Section 230 has frequently been referred as a key law that has allowed the Internet to flourish, often referred to as “The Twenty-Six Words That Created the Internet”.

History

Prior to the Internet, case law was clear that a liability line was drawn between publishers of content and distributors of content; publishers would be expected to have awareness of material it was publishing and thus should be held liable for any illegal content it published, while distributors would likely not be aware and thus would be immune. This was established in Smith v. California (1959), where the Supreme Court ruled that putting liability on the provider (a book store in this case) would have “a collateral effect of inhibiting the freedom of expression, by making the individual the more reluctant to exercise it.”^[1]

In the early 1990s, the Internet became more widely adopted and created means for users to engage in forums and other user-generated content. While this helped to expand the use of the Internet, it also resulted in a number of legal cases putting service providers at fault for the content generated by its users. This concern was raised by legal challenges against CompuServe and Prodigy, early service providers at this time.^[2] CompuServe stated they would not attempt to regulate what users posted on their services, while Prodigy had employed a team of moderators to validate content. Both faced legal challenges related to content posted by their users. In Cubby, Inc. v. CompuServe Inc., CompuServe was found not be at fault as, by its stance as allowing all content to go unmoderated, it was a distributor and thus not liable for libelous content posted by users. However, Stratton Oakmont, Inc. v. Prodigy Services Co. found that as Prodigy had taken an editorial role with regard to customer content, it was a publisher and legally responsible for libel committed by customers.^[3]^[a]

Chris Cox (left) and Ron Wyden, the framers of Section 230

Service providers made their Congresspersons aware of these cases, believing that if upheld across the nation, it would stifle the growth of the Internet. United States Representative Christopher Cox (R-CA) had read an article about the two cases and felt the decisions were backwards. “It struck me that if that rule was going to take hold then the internet would become the Wild West and nobody would have any incentive to keep the internet civil”, Cox stated.^[4]

At the time, Congress was preparing the Communications Decency Act (CDA), part of the omnibus Telecommunications Act of 1996, which was designed to make knowingly sending indecent or obscene material to minors a criminal offense. A version of the CDA had passed through the Senate pushed by Senator J. James Exon.^[5] A grassroots effort in the tech industry reacted to try to convince the House of Representatives to challenge Exon’s bill. Based on the Stratton Oakmont decision, Congress recognized that by requiring service providers to block indecent content would make them be treated as publishers in context of the First Amendment and thus become liable for other illegal content such as libel, not set out in the existing CDA.^[2] Cox and fellow Representative Ron Wyden (D-OR) wrote the House bill’s section 509, titled the Internet Freedom and Family Empowerment Act, designed to override the decision from Stratton Oakmont, so that services providers could moderate content as necessary and did not have to act as a wholly neutral conduit. The new Act was added the section while the CDA was in conference within the House.

The overall Telecommunications Act, with both Exon’s CDA and Cox/Wyden’s provision, passed both Houses by near-unanimous votes and signed into law by President Bill Clinton by February 1996.^[6] Cox/Wyden’s section was codified as Section 230 in Title 47 of the US Code. The anti-indecency portion of the CDA was immediately challenged on passage, resulting in the Supreme Court 1997 case, Reno v. American Civil Liberties Union, that ruled all of the anti-indecency sections of the CDA were unconstitutional, but left Section 230.^[7]

One of the first legal challenges to Section 230 was the 1997 case Zeran v. America Online, Inc., in which a Federal court affirmed that the purpose of Section 230 as passed by Congress was “to remove the disincentives to self-regulation created by the Stratton Oakmont decision”.^[8] Under that court’s holding, computer service providers who regulated the dissemination of offensive material on their services risked subjecting themselves to liability, because such regulation cast the service provider in the role of a publisher. Fearing that the specter of liability would therefore deter service providers from blocking and screening offensive material, Congress enacted § 230’s broad immunity “to remove disincentives for the development and utilization of blocking and filtering technologies that empower parents to restrict their children’s access to objectionable or inappropriate online material.”^[8] In addition, Zeran notes “the amount of information communicated via interactive computer services is . . . staggering. The specter of tort liability in an area of such prolific speech would have an obviously chilling effect. It would be impossible for service providers to screen each of their millions of postings for possible problems. Faced with potential liability for each message republished by their services, interactive computer service providers might choose to severely restrict the number and type of messages posted. Congress considered the weight of the speech interests implicated and chose to immunize service providers to avoid any such restrictive effect.”^[8]

Application and limits

In analyzing the availability of the immunity offered by Section 230, courts generally apply a three-prong test. A defendant must satisfy each of the three prongs to gain the benefit of the immunity:^[9]

The defendant must be a “provider or user” of an “interactive computer service.”
The cause of action asserted by the plaintiff must treat the defendant as the “publisher or speaker” of the harmful information at issue.
The information must be “provided by another information content provider,” i.e., the defendant must not be the “information content provider” of the harmful information at issue.

Section 230 immunity is not unlimited. The statute specifically excepts federal criminal liability and intellectual property claims.^[10] However, state criminal laws have been held preempted in cases such as Backpage.com, LLC v. McKenna^[11] and Voicenet Commc’ns, Inc. v. Corbett^[12] (agreeing “[T]he plain language of the CDA provides … immunity from inconsistent state criminal laws.”).

As of mid-2016, courts have issued conflicting decisions regarding the scope of the intellectual property exclusion set forth in 47 U.S.C. § 230(e)(2). For example, in Perfect 10, Inc. v. CCBill, LLC,^[13] the 9th Circuit Court of Appeals ruled that the exception for intellectual property law applies only to federal intellectual property claims such as copyright infringement, trademark infringement, and patents, reversing a district court ruling that the exception applies to state-law right of publicity claims.^[14] The 9th Circuit’s decision in Perfect 10 conflicts with conclusions from other courts including Doe v. Friendfinder. The Friendfinder court specifically discussed and rejected the lower court’s reading of “intellectual property law” in CCBill and held that the immunity does not reach state right of publicity claims.^[15]

Additionally, with the passage of the Digital Millennium Copyright Act in 1998, services provides must comply with additional requirements for copyright infringement to maintain “safe harbor” protections from liability, as defined in the DMCA’s Title II, Online Copyright Infringement Liability Limitation Act.^[16]

Controversies

The first major challenge to Section 230 was in Zeran v. AOL, a 1997 case decided at the Fourth Circuit. The case involved a person that sued America Online (AOL) for failing to remove, in a timely manner, libelous ads posted by AOL users that inappropriately connected his home phone number to the Oklahoma City bombing. The court found for AOL and upheld the constitutionality of Section 230, stating that Section 230 “creates a federal immunity to any cause of action that would make service providers liable for information originating with a third-party user of the service.”^[17] This rule, cementing Section 230’s liability protections, has been considered one of the most important case laws affecting the growth of the Internet, allowing websites to be able to incorporate user-generated content without fear of prosecution.^[18] However, at the same time, this has led to Section 230 being used as a shield for some website owners as courts have ruled Section 230 provides complete immunity for ISPs with regard to the torts committed by their users over their systems.^[19]

Sex trafficking

Around 2001, a University of Pennsylvania paper warned that “online sexual victimization of American children appears to have reached epidemic proportions” due to the allowances granted by Section 230.^[20] Over the next decade, advocates against such exploitation such as the National Center for Missing and Exploited Children pressured major websites to block or remove content related to sex trafficking, leading to sites like Facebook, MySpace, and Craigslist to pull such content. Because mainstream sites were blocking this content, those that engaged or profited from trafficking started to use more obscure sites, leading to the creation of sites like Backpage. In addition to removing these from the public eye, these new sites worked to obscure what trafficking was going on and who was behind it, limiting ability for law enforcement to take action.^[20] Backpage and similar sites quickly came under numerous lawsuits from victims of the sex traffickers and exploiters for enabling this crime, but the court continually found in favor of Backpage due to Section 230,^[21] and the Supreme Court let stand a Circuit Court decision in favor of Backpage due to Section 230 in January 2017.^[22]

Due to numerous complaints from constituents, Congress began an investigation into Backpage and similar sites in January 2017, finding Backpage complicit in aiding and profiting from illegal sex trafficking.^[23] Subsequently, Congress introduced the FOSTA-SESTA bills: the Allow States and Victims to Fight Online Sex Trafficking Act (FOSTA) in the House of Representatives by Ann Wagner in April 2017, and the Stop Enabling Sex Traffickers Act (SESTA) U.S. Senate bill introduced by Rob Portman in August 2017. Combined, the FOSTA-SESTA bills modified Section 230 to exempt services providers from Section 230 immunity when dealing with civil or criminal crimes related to sex trafficking,^[24] which removes section 230 safe harbors for services that knowingly facilitate or support sex trafficking.^[25] The bill passed both Houses and was signed into law by President Donald Trump on April 11, 2018.^[26]^[27]

The bills were criticized by pro-free speech and pro-Internet groups as a “disguised internet censorship bill” that weakens the section 230 safe harbors, places unnecessary burdens on Internet companies and intermediaries that handle user-generated content or communications with service providers required to proactively take action against sex trafficking activities, and requires a “team of lawyers” to evaluate all possible scenarios under state and federal law (which may be financially unfeasible for smaller companies).^[28]^[29]^[30]^[31]^[32] Critics also argued that FOSTA-SESTA did not distinguish between consensual, legal sex offerings from non-consensual ones, and argued it would cause websites otherwise engaged in legal offerings of sex work would be threatened with liability charges.^[23] Online sex workers argued that the bill would harm their safety, as the platforms they utilize for offering and discussing sexual services in a legal manner (as an alternative to street prostitution) had begun to reduce their services or shut down entirely due to the threat of liability under the bill.^[33]^[34]

Social media

Many social media sites, notably Facebook and Twitter, came under scrutiny as a result of the alleged Russian interference in the 2016 United States elections, where it was alleged that Russian agents used the sites to spread propaganda and fake news to swing the election in favor of Donald Trump. These platforms also were criticized for not taking action against users that used the social media outlets for harassment and hate speech against others. Shortly after the passage of FOSTA-SESTA acts, some in Congress recognized that additional changes could be made to Section 230 to require service providers to deal with these bad actors, beyond what Section 230 already provided to them.^[35] During 2019, there have been renewed calls for changes in Section 230 to address what are seen as growing problems across social media and the protections given to tech companies.

Platform neutrality

Some politicians, including Republican senators Ted Cruz and Josh Hawley, have accused major social networks of displaying a bias against conservative perspectives when moderating content (such as Twitter suspensions).^[36]^[36]^[37]^[38] In a Fox News op-ed, Cruz argued that section 230 should only apply to providers that are politically “neutral”, suggesting that a provider “should be considered to be a [liable] ‘publisher or speaker’ of user content if they pick and choose what gets published or spoke.”^[39] Section 230 does not contain any requirements that moderation decisions be neutral.^[39] Hawley alleged that section 230 safe harbors were a “sweetheart deal between big tech and big government”.^[40]^[41]

In December 2018, Republican house representative Louie Gohmert introduced the Biased Algorithm Deterrence Act (H.R.492), which would remove all section 230 protections for any provider that used filters or any other type of algorithms to display user content when otherwise not directed by a user.^[42]^[43]

In June 2019, Hawley introduced the Ending Support for Internet Censorship Act (S. 1914), that would remove section 230 protections from companies whose services have more than 30 million active monthly users in the U.S. and more than 300 million worldwide, or have over $500 million in annual global revenue, unless they receive a certification from the majority of the Federal Trade Commission that they do not moderate against any political viewpoint, and have not done so in the past 2 years.^[44]^[45]

There has been criticism—and support—of the proposed bill from various points on the political spectrum. A poll of more than 1,000 voters gave Senator Hawley’s bill a net favorability rating of 29 points among Republicans (53% favor, 24% oppose) and 26 points among Democrats (46% favor, 20% oppose).^[46] Some Republicans feared that by adding FTC oversight, the bill would continue to fuel fears of a big government with excessive oversight powers.^[47] Democrat Speaker Nancy Pelosi has indicated support for the same approach Hawley has taken.^[48] The chairman of the Senate Judiciary Committee, Senator Graham, has also indicated support for the same approach Hawley has taken, saying “he is considering legislation that would require companies to uphold ‘best business practices’ to maintain their liability shield, subject to periodic review by federal regulators.” ^[49]

Legal experts have criticized the Republicans’ push to make Section 230 encompass platform neutrality. Wyden stated in response to potential law changes that “Section 230 is not about neutrality. Period. Full stop. 230 is all about letting private companies make their own decisions to leave up some content and take other content down.”^[50] Law professor Jeff Kosseff, who has written extensively on Section 230, has stated that the Republican intentions are based on a “fundamental misunderstanding” of Section 230’s purpose, as platform neutrality was not one of the considerations made at the time of passage.^[51] Kosseff stated that political neutrality was not the intent of Section 230 according to the framers, but rather making sure providers had the ability to make content-removal judgement without fear of liability.^[2] There have been concerns that any attempt to weaken Section 230 could actually cause an increase in censorship when services lose their liability.^[41]^[52]

Hate speech

In the wake of the 2019 shootings in Christchurch, New Zealand, El Paso, Texas and Dayton, Ohio, the impact on Section 230 and liability towards online hate speech has been raised. In both the Christchurch and El Paso shootings, the perpetrator posted hate speech manifestos to 8chan, a moderated imageboard known to be favorable for the posting of extreme views. Concerned politicians and citizens raised calls at large tech companies for the need for hate speech to be removed from the Internet; however, hate speech is generally protected speech under the First Amendment, and Section 230 removes the liability for these tech companies to moderate such content as long as it is not illegal. This has given the appearance that tech companies do not need to be proactive against hateful content, thus allowing the hate content to fester online and lead to such incidents.^[53]^[5]

Notable articles on this concerns were published after the El Paso shooting by The New York Times,^[53] The Wall Street Journal,^[54] and Bloomberg Businessweek,^[5] among other outlets, but which were criticized by legal experts including Mike Godwin, Mark Lemley, and David Kaye, as the articles implied that hate speech was protected by Section 230, when it is in fact protected by the First Amendment. In the case of The New York Times, the paper issued a correction to affirm that the First Amendment protected hate speech, and not Section 230.^[55]^[56]^[57]

Members of Congress have indicated they may pass a law that changes how Section 230 would apply to hate speed as to make tech companies liable for this. Wyden, now a Senator, stated that he intended for Section 230 to be both “a sword and a shield” for Internet companies, the “sword” allowing them to remove content they deem inappropriate for their service, and the shield to help keep offensive content their from sites without liability. However, Wyden argued that become tech companies have not been willing to use the sword to remove content, it is necessary to take away that shield.^[53]^[5] Some have compared Section 230 to the Protection of Lawful Commerce in Arms Act, a law that grants gun manufacturers immunity from certain types of lawsuits when their weapons are used in criminal acts. According to law professor Mary Anne Franks, “They have not only let a lot of bad stuff happen on their platforms, but they’ve actually decided to profit off of people’s bad behavior.”^[5] Representative Beto O’Rourke has stated his intent for his 2020 presidential campaign to introduce sweeping changes to Section 230 to make Internet companies liable for not being proactive in taking down hate speech.^[58]

Terrorism-related content

In the aftermath of the Backpage trial and subsequent passage of FOSTA-SESTA, others have found that Section 230 appears to protect tech companies from content that is otherwise illegal under United States law. Professor Danielle Citron and journalist Benjamin Wittes found that as late as 2018, several groups deemed as terrorist organizations by the United States had been able to maintain social media accounts on services run by American companies, despite federal laws that make providing material support to terrorist groups subject to civil and criminal charges.^[59] However, case law from the Second Circuit has ruled that under Section 230, technology companies are not liable for civil claims based on terrorism-related content.^[60]

Case law

Defamatory information

Zeran v. AOL, 129 F.3d 327 (4th Cir. 1997).^[61]

Immunity was upheld against claims that AOL unreasonably delayed in removing defamatory messages posted by third party, failed to post retractions, and failed to screen for similar postings.

Blumenthal v. Drudge, 992 F. Supp. 44, 49-53 (D.D.C. 1998).^[62]

The court upheld AOL’s immunity from liability for defamation. AOL’s agreement with the contractor allowing AOL to modify or remove such content did not make AOL the “information content provider” because the content was created by an independent contractor. The Court noted that Congress made a policy choice by “providing immunity even where the interactive service provider has an active, even aggressive role in making available content prepared by others.”

Carafano v. Metrosplash.com, 339 F.3d 1119 (9th Cir. 2003).^[63]

The court upheld immunity for an Internet dating service provider from liability stemming from third party’s submission of a false profile. The plaintiff, Carafano, claimed the false profile defamed her, but because the content was created by a third party, the website was immune, even though it had provided multiple choice selections to aid profile creation.

Batzel v. Smith, 333 F.3d 1018 (9th Cir. 2003).^[64]

Immunity was upheld for a website operator for distributing an email to a listserv where the plaintiff claimed the email was defamatory. Though there was a question as to whether the information provider intended to send the email to the listserv, the Court decided that for determining the liability of the service provider, “the focus should be not on the information provider’s intentions or knowledge when transmitting content but, instead, on the service provider’s or user’s reasonable perception of those intentions or knowledge.” The Court found immunity proper “under circumstances in which a reasonable person in the position of the service provider or user would conclude that the information was provided for publication on the Internet or other ‘interactive computer service’.”

Green v. AOL, 318 F.3d 465 (3rd Cir. 2003).^[65]

The court upheld immunity for AOL against allegations of negligence. Green claimed AOL failed to adequately police its services and allowed third parties to defame him and inflict intentional emotional distress. The court rejected these arguments because holding AOL negligent in promulgating harmful content would be equivalent to holding AOL “liable for decisions relating to the monitoring, screening, and deletion of content from its network — actions quintessentially related to a publisher’s role.”

Barrett v. Rosenthal, 40 Cal. 4th 33 (2006).^[66]

Immunity was upheld for an individual internet user from liability for republication of defamatory statements on a listserv. The court found the defendant to be a “user of interactive computer services” and thus immune from liability for posting information passed to her by the author.

MCW, Inc. v. badbusinessbureau.com(RipOff Report/Ed Magedson/XCENTRIC Ventures LLC) 2004 WL 833595, No. Civ.A.3:02-CV-2727-G (N.D. Tex. April 19, 2004).^[67]

The court rejected the defendant’s motion to dismiss on the grounds of Section 230 immunity, ruling that the plaintiff’s allegations that the defendants wrote disparaging report titles and headings, and themselves wrote disparaging editorial messages about the plaintiff, rendered them information content providers. The Web site, http://www.badbusinessbureau.com, allows users to upload “reports” containing complaints about businesses they have dealt with.

Hy Cite Corp. v. badbusinessbureau.com (RipOff Report/Ed Magedson/XCENTRIC Ventures LLC), 418 F. Supp. 2d 1142 (D. Ariz. 2005).^[68]

The court rejected immunity and found the defendant was an “information content provider” under Section 230 using much of the same reasoning as the MCW case.

False information

Gentry v. eBay, Inc., 99 Cal. App. 4th 816, 830 (2002).^[69]

eBay‘s immunity was upheld for claims based on forged autograph sports items purchased on the auction site.

Ben Ezra, Weinstein & Co. v. America Online, 206 F.3d 980, 984-985 (10th Cir. 2000), cert. denied, 531 U.S. 824 (2000).^[70]

Immunity for AOL was upheld against liability for a user’s posting of incorrect stock information.

Goddard v. Google, Inc., C 08-2738 JF (PVT), 2008 WL 5245490, 2008 U.S. Dist. LEXIS 101890 (N.D. Cal. Dec. 17, 2008).^[71]

Immunity was upheld against claims of fraud and money laundering. Google was not responsible for misleading advertising created by third parties who bought space on Google’s pages. The court found the creative pleading of money laundering did not cause the case to fall into the crime exception to Section 230 immunity.

Milgram v. Orbitz Worldwide, LLC, ESX-C-142-09 (N.J. Super. Ct. Aug. 26, 2010).^[72]

Immunity for Orbitz and CheapTickets was upheld for claims based on fraudulent ticket listings entered by third parties on ticket resale marketplaces.

Herrick v. Grindr, 18-396

The Second Circuit upheld immunity for the Grindr dating app for LGBT persons under Section 230 in regards to the misuse of false profiles created in the names of a real person. The plaintiff had broken up with a boyfriend, who later went onto Grindr to create multiple false profiles that presented the real-life identity and address of the plaintiff and as being available for sexual encounters, as well as having illegal drugs for sale. The plaintiff reported that over a thousand men had come to his house for sex and drugs, based on the communications with the fake profile, and he began to fear for his safety. He sued Grindr for not taking actions to block the false profiles after multiple requests. Grindr asserted Section 230 did not make them liable for the actions of the ex-boyfriend. This was agreed by the district court and the Second Circuit.^[73]^[74]

Sexually explicit content and minors

Doe v. America Online, 783 So. 2d 1010, 1013-1017 (Fl. 2001),^[75] cert. denied, 122 S.Ct. 208 (2000).

The court upheld immunity against state claims of negligence based on “chat room marketing” of obscene photographs of minor by a third party.

Kathleen R. v. City of Livermore, 87 Cal. App. 4th 684, 692 (2001).^[76]

The California Court of Appeal upheld the immunity of a city from claims of waste of public funds, nuisance, premises liability, and denial of substantive due process. The plaintiff’s child downloaded pornography from a public library’s computers, which did not restrict access to minors. The court found the library was not responsible for the content of the internet and explicitly found that section 230(c)(1) immunity covers governmental entities and taxpayer causes of action.

Doe v. MySpace, 528 F.3d 413 (5th Cir. 2008).^[77]

The court upheld immunity for a social networking site from negligence and gross negligence liability for failing to institute safety measures to protect minors and failure to institute policies relating to age verification. The Does’ daughter had lied about her age and communicated over MySpace with a man who later sexually assaulted her. In the court’s view, the Does’ allegations were “merely another way of claiming that MySpace was liable for publishing the communications.”

Dart v. Craigslist, Inc., 665 F. Supp. 2d 961 (N.D. Ill. Oct. 20, 2009).^[78]

The court upheld immunity for Craigslist against a county sheriff’s claims that its “erotic services” section constituted a public nuisance because it caused or induced prostitution.

Backpage.com v. McKenna, et al., CASE NO. C12-954-RSM^[79]
Backpage.com LLC v Cooper, Case #: 12-cv-00654[SS1]^[80]
Backpage.com LLC v Hoffman et al., Civil Action No. 13-cv-03952 (DMC) (JAD)^[81]

The court upheld immunity for Backpage in contesting a Washington state law (SB6251)^[82] that would have made providers of third-party content online liable for any crimes related to a minor in Washington state.^[83] The states of Tennessee and New Jersey later passed similar legislation. Backpage argued that the laws violated Section 230, the Commerce Clause of the United States Constitution, and the First and Fifth Amendments.^[82] In all three cases the courts granted Backpage permanent injunctive relief and awarded them attorney’s fees.^[80]^[84]^[85]^[86]^[87]

Backpage.com v. Dart., CASE NO. 15-3047^[88]

The court ruled in favor of Backpage after Sheriff Tom Dart of Cook County IL, a frequent critic of Backpage and its adult postings section, sent a letter on his official stationary to Visa and MasterCard demanding that these firms “immediately cease and desist” allowing the use of their credit cards to purchase ads on Backpage. Within two days both companies withdrew their services from Backpage.^[89] Backpage filed a lawsuit asking for a temporary restraining order and preliminary injunction against Dart granting Backpage relief and return to the status quo prior to Dart sending the letter. Backpage alleged that Dart’s actions were unconstitutional, violating the First and Fourteenth Amendments to the US Constitution as well as Section 230 of the CDA. Backpage asked for Dart to retract his “cease and desist” letters.^[90] After initially being denied the injunctive relief by a lower court,^[91]^[92] the Seventh Circuit U.S. Court of Appeals reversed that decision and directed that a permanent injunction be issued enjoining Dart and his office from taking any actions “to coerce or threaten credit card companies…with sanctions intended to ban credit card or other financial services from being provided to Backpage.com.”^[93] The court cited section 230 as part of its decision.

Discriminatory housing ads

Chicago Lawyers’ Committee For Civil Rights Under Law, Inc. v. Craigslist, Inc. 519 F.3d 666 (7th Cir. 2008).^[94]

The court upheld immunity for Craigslist against Fair Housing Act claims based on discriminatory statements in postings on the classifieds website by third party users.

In February 2012, the Ninth Circuit decided in THE FOLLOWING 2008 RULING, that Roommates.com did not violate the FHA because roommate selection is protected under the First Amendment, and it dismissed the case. This decision did not find the prior 2008 ruling to be reversed. Fair Housing Council of San Fernando Valley v. Roommate.com, LLC, 2012 WL 310849 (9th Cir. February 2, 2012).
Fair Housing Council of San Fernando Valley v. Roommates.com, LLC, 521 F.3d 1157 (9th Cir. 2008) (en banc).^[95]

The Ninth Circuit Court of Appeals rejected immunity for the Roommates.com roommate matching service for claims brought under the federal Fair Housing Act^[96] and California housing discrimination laws.^[97] The court concluded that the manner in which the service elicited information from users concerning their roommate preferences (by having dropdowns specifying gender, presence of children, and sexual orientation), and the manner in which it utilized that information in generating roommate matches (by eliminating profiles that did not match user specifications), the matching service created or developed the information claimed to violate the FHA, and thus was responsible for it as an “information content provider.” The court upheld immunity for the descriptions posted by users in the “Additional Comments” section because these were entirely created by users.

Threats

Delfino v. Agilent Technologies, 145 Cal. App. 4th 790 (2006), cert denied, 128 S. Ct. 98 (2007).

A California Appellate Court unanimously upheld immunity from state tort claims arising from an employee’s use of the employer’s e-mail system to send threatening messages. The court concluded that an employer that provides Internet access to its employees qualifies as a “provider . . . of an interactive service.”

Failure to warn

Jane Doe No. 14 v. Internet Brands, Inc., No. 12-56638 (9th Cir. Sept. 17, 2014).

The Ninth Circuit Court of Appeals rejected immunity for claims of negligence under California law. Doe filed a complaint against Internet Brands which alleged a “failure to warn” her of a known rape scheme, despite her relationship to them as a ModelMayhem.com member. They also had requisite knowledge to avoid future victimization of ModelMayhem.com users by warning users of online sexual predators. The Ninth Circuit Court of Appeals concluded that the Communications Decency Act did not bar the claim and remanded the case to the district court for further proceedings.

In February 2015, the Ninth Circuit panel set aside its 2014 opinion and set the case for reargument. In May 2016, the panel again held that Doe’s case could proceed.^[98]^[99]

Terrorism

Force v. Facebook, Inc., No. 18-397 (2d Cir. July 31, 2019)

The Second Circuit upheld immunity in civil claims for service providers for hosting terrorism-related content created by users. Families, friends, and associates of several killed in Hamas-attacks filed suit against Facebook under the United State’s Anti-Terrorism Act, asserting that since Hamas members used Facebook to coordinate activities, Facebook was liable for its content. While previous rules at federal District and Circuit level have generally ruled against such cases, this decision in the Second Circuit was first to assert that Section 230’s safe harbor provisions do apply even to acts related to terrorism that may be posted by users of service providers, thus dismissing the suit against Facebook. The Second Circuit ruled that the various algorithms Facebook uses to recommend content remains as part of the role of the distributor of the content and not the publisher, since these automated tools were essentially neutral.^[60]

Similar legislation in other countries]

European Union

Directive 2000/31/EC^[100] establishes a safe haven regime for hosting providers:

Article 14 establishes that hosting providers are not responsible for the content they host as long as (1) the acts in question are neutral intermediary acts of a mere technical, automatic and passive capacity; (2) they are not informed of its illegal character, and (3) they act promptly to remove or disable access to the material when informed of it.
Article 15 precludes member states from imposing general obligations to monitor hosted content for potential illegal activities.

The updated Directive on Copyright in the Digital Single Market (Directive 2019/790) Article 17 makes providers liable if they fail to take “effective and proportionate measures” to prevent users from uploading certain copyright violations and do not response immediately to takedown requests.^[101]

Australia

In Dow Jones & Company Inc v Gutnick,^[102] the High Court of Australia treated defamatory material on a server outside Australia as having been published in Australia when it is downloaded or read by someone in Australia.

Gorton v Australian Broadcasting Commission & Anor (1973) 1 ACTR 6

Under the Defamation Act 2005 (NSW),^[103] s 32, a defence to defamation is that the defendant neither knew, nor ought reasonably to have known of the defamation, and the lack of knowledge was not due to the defendant’s negligence.

New Zealandcause of the material CompuServe’s network was carrying into Germany. He was convicted and sentenced to two years probation on May 28, 1998.^[104]^[105] He was cleared on appeal on November 17, 1999.^[106]^[107]

The Oberlandesgericht (OLG) Cologne, an appellate court, found that an online auctioneer does not have an active duty to check for counterfeit goods (Az 6 U 12/01).^[108]

In one example, the first-instance district court of Hamburg issued a temporary restraining order requiring message board operator Universal Boards to review all comments before they can be posted to prevent the publication of messages inciting others to download harmful files. The court reasoned that “the publishing house must be held liable for spreading such material in the forum, regardless of whether it was aware of the content.”^[109]

United Kingdom

Also see: Defamation Act 2013.

The laws of libel and defamation will treat a disseminator of information as having “published” material posted by a user, and the onus will then be on a defendant to prove that it did not know the publication was defamatory and was not negligent in failing to know: Goldsmith v Sperrings Ltd (1977) 2 All ER 566; Vizetelly v Mudie’s Select Library Ltd (1900) 2 QB 170; Emmens v Pottle & Ors (1885) 16 QBD 354.

In an action against a website operator, on a statement posted on the website, it is a defence to show that it was not the operator who posted the statement on the website. The defence is defeated if it was not possible for the claimant to identify the person who posted the statement, or the claimant gave the operator a notice of complaint and the operator failed to respond in accordance with regulations.

Notes

^ The details of the Stratton Oakmont case would later serve as the basis for the book and its film The Wolf of Wall Street

References …

47 U.S.C. § 230
Margaret Jane Radin et al., Internet Commerce: The Emerging Legal Framework 1091-1136 (2nd ed. 2006)
The Universal Declaration of Human Rights – Article 12
International Covenant on Civil and Political Rights – Article 17 (1), (2)
U.S. reservations, declarations, and understandings, International Covenant on Civil and Political Rights, 138 Cong. Rec. S4781-01 (daily ed., April 2, 1992). Section II (5)

External links

https://en.wikipedia.org/wiki/Section_230_of_the_Communications_Decency_Act

[4] The details of the Stratton Oakmont case would later serve as the basis for the book and its film The Wolf of Wall Street

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Chart (1973)	Peak position
Australia (Kent Music Report)^[22]	1
Austria (Ö3 Austria Top 40)^[23]	19
Canada (RPM)^[24]	1
Ireland (IRMA)	10
Netherlands (Dutch Top 40)^[25]	3
Norway (VG-lista)^[26]	4
Switzerland (Schweizer Hitparade)^[27]	32
UK Singles (The Official Charts Company)^[28]	6
US Billboard Hot 100^[29]	1
US Hot R&B Singles^[30]	2
US Easy Listening^[30]	2
West Germany (Official German Charts)^[31]	30

Artist	Album	Year Released
Perry Como	And I Love You So	1973
Vicki Lawrence	The Night the Lights Went Out in Georgia	1973
Eric Gale	Forecast	1973
The Jacksons 5		1974
The Undisputed Truth	Law of the Land	1973
Dottie West	If It’s All Right With You / Just What I’ve Been Looking For	1973
Johnny Mathis	Killing Me Softly with Her Song	1973
Lynn Anderson	Top of the World	1973
Bobby Goldsboro	Summer (The First Time)	1973
Rusty Bryant	For the Good Times	1973
Vikki Carr	Ms. America	1973
Sergio Mendes & Brasil ’77	Love Music	1973
The Ventures	Only Hits!	1973
Ellen	Freckles	1973
John Holt	1000 Volts of Holt	1973
Anne Murray	Danny’s Song	1973
Tim Weisberg	Dreamspeaker	1973
Maynard Parker	Midnight Rider	1973
The Hiltonaires	Made in England 6	1973
Shirley Bassey	Never, Never, Never	1973
Ray Conniff and The Singers	You Are the Sunshine of My Life	1973
Clint Holmes	Playground in My Mind	1973
Elaine Delmar	Elaine Delmar	1973
New World	Believe in Music	1973
Gianni Oddi	Oddi	1973
Perry Como	And I Love You So	1973
Andy Williams	The Way We Were	1974
Petula Clark	Come on Home	1974
Charlie Byrd	Byrd by the Sea	1974
Janice Hoyte	I’m a Winner	1974
Ed Kilbourne	Missionary	1974
Joy Fleming	Live	1974
Frances Yip	Frances Scores Hits	1974
Engelbert Humperdinck	My Love	1974
Ohashi Junko	Feeling Now	1974
Lena Martell	That Wonderful Sound of Lena Martell	1974
Piet Noordijk	Prototype	1974
Swingle II	Words and Music	1974
Aura	Oh, My Love	1974
Jr. Walker & The All Stars	Jr. Walker & The All Stars	1974
Bobby Vinton	The Bobby Vinton Show	1975
The Les Humphries Singers	The Les Humphries Singers Live	1975
Peters & Lee	Favorites	1975
The Geoff Love Singers	Close to You	1975
Vince Hill	Mandy	1975
The Singers Unlimited	A Capella II	1975
Tuxen	Smilin’ Steel	1975
Therapy	Bringing the House Down	1975
Peter North	Saxomania	1975
Sandra Reemer	Trust In Me	1976
Cleo Laine & John Williams	Best Friends	1976
The Brothers Four	New	1976
Brenda Lee	Just for You – Something Nice	1976
Val Doonican	Some of My Best Friends Are Songs	1977
Rita Remington	Magical, Musical, Memories	1978
Hampton Hawes	At the Piano	1978
Howard Carpendale	Und so geh’n wir unsere Wege	1978
Precious Wilson	On the Race Track	1980
Roberta Flack & Peabo Bryson	Live & More	1980
Kimiko Kasai	Love Talk	1984
The Eddy Starr Singers	28 Golden Love Songs	1984
Mina	Finalmente ho conosciuto il conte Dracula vol. 1	1985
Al B. Sure!	In Effect Mode	1988
Casal	Histeria	1989
Samurai & Hardbartle	SynTronic MegaHits	1990
Linda Imperial	Killing Me Softly (Single)	1991
Pandora	Matandome Suavemente	1992
Des’ree	Why Should I Love You?	1992
Päivi Mäkinen & Mökö	Rakkaudesta elämään	1993
Amii Stewart	Lady to Ladies	1994
Curiosity	Back to Front	1994
Ron Sanfilippo	Now and Then	1994
Luther Vandross	Songs	1994
Extempo	Channel 32	1995
Cassandra Wilson	Spirit of ’73 – Rock for Choice	1995
Fugees	The Score	1996
Michelle	Avex Reggae System Vol. 7	1996
Destroy All Monsters	Silver Wedding Anniversary	1996
The Spades	Killing Me Softly (Single)	1996
Georgetown Phantoms	Spank Your Eardrum	1997
Siiri, Boris Björn Bagger & the International Acoustic Band	1st Acoustic Grafitti	1997
Gitte Hænning	My Favorite Songs	1998
Victoria Abril	Enciende mi pasión	1998
Nils Landgren	Ballads	1999
The BB Band	That Soul Sound of the 70’s	1999
Cindy Scott	Red Hot – Cindy Scott Captured Live in England	2002
Susan Wong	Close to You	2002
Marianna Leporace	Pop Acústico	2002
Chenoa	Mis canciones favoritas – En concierto acústico	2003
Kimberly Caldwell	American Idol Season 2 – All-Time Classic American Love Songs	2003
Cheryl Bentyne	The Lights Still Burn	2003
Captain Smartypants	Undercover	2004
Coco d’Or	Coco d’Or 2	2006
Perpetuum Jazzile	Čudna Noč	2006
Don Latarski and Marilyn Keller	Nightingale	2006
Michael Sagmeister	Soul Ticket	2006
The Mardi Gras Band	Requests	2007
Georgeana Bonow	Pop Bossa – When Pop Goes Bossa	2008
Deborah Sasson	Pop Classics	2008
Layla Zoe	Live at Errington Hall	2008
Starburkes & The Tea Leaf	Acoustic Coffee House	2009
Colbie Caillat	iTunes Session	2010
Shanti Snyder	Born to Sing	2010
Chelsey Forrest, Kirk Smart	Talk to Me Nice	2010
Soul Kitchen-Band feat. Gail Anderson	15 Years Soul Kitchen – The Band	2011
Virginia Belles	Good Morning Mr. Jefferson	2011
Afro Blue	The Sing-Off Season 3 Episode 6 – Hip Hop (Album)	2011
Harvard Opportunes	Out Loud	2011
Joanie Samra – Jesse Green	Serendipity	2011
Ruth Jacott	Simply the Best – One Woman Show	2012
Katrina Parker	The Voice – Killing Me Softly with His Song (Single)	2012
Sussan Kameron	Romantic Nights	2012
Keiko Lee	Keiko Lee Sings Super Standards 2	2012
Connie Evingson	Sweet Happy Life	2012
Sydney Claire	Rocks in My Bed	2012
Gary Brown	Generations	2012
The Dear Abbeys	Proclamation	2012
Miss Murphy	The Voice [AU] – Killing Me Softly (Single)	2013
Keaira LaShae	The Voice – Killing Me Softly with His Song (Single)	2013
Nancy Sinatra	Shifting Gears	2013
Lulu Roman	At Last	2013
Ale Vanzella	Indie Bossa II	2015
Norah Benatia	IDOL 2016 Topp 3 (EP)	2016
Joseph Vincent	Killing Me Softly (Single)	2016
Scott & Ben	Scott & Ben – Acoustic Cover Sessions Volume 2	2016
Meg Birch	Acoustic Covers Pop	2017
Scary Pockets feat. India Carney	Nu Funk	2017
Alyssa Bernal	Killing Me Softly (Single)	2017
Nicole Cross	Shapeshifter	2018

Household Size	Gross monthly income (130 percent of poverty)	Net monthly income (100 percent of poverty)
1	$1,307	$ 1,005
2	$1,760	$1,354
3	$2,213	$1,702
4	$2,665	$2,050
5	$3,118	$2,399
6	$3,571	$2,747
7	$4,024	$3,095
8	$4,477	$3,444
Each additional member	+$453	+$349

Gross Income Calculation	Example
Determine household size . . .	4 people with no elderly or disabled members.
Add gross monthly income . . .	$1,500 earned income + $550 social security = $2,050 gross income.
If gross monthly income is less than the limit for household size, determine net income.	$2,050 is less than the $2,665 allowed for a 4-person household, so determine net income.

Net Income Calculation	Example
Subtract 20% earned income deduction . . .	$2,050 gross income $1,500 earned income x 20% = $300. $2,050 – $300 = $1,750
Subtract standard deduction . . .	$1,750 – $170 standard deduction for a 4-person household = $1,580
Subtract dependent care deduction . . .	$1,580 – $361 dependent care = $1,219
Subtract child support deduction . . .	0
Subtract medical costs over $35 for elderly and disabled . . .	0
Excess shelter deduction . . .
Determine half of adjusted income . . .	$1,219 adjusted income/2 = $609.50
Determine if shelter costs are more than half of adjusted income . . .	$700 total shelter – $609 (half of income) = $90 excess shelter cost
Subtract excess amount, but not more than the limit, from adjusted income . . .	$1,219 – $90.50 = $1,128.50 Net monthly income
Apply the net income test . . .	Since the net monthly income is less than $2,050 allowed for 4-person household, the household has met the income test.

People in Household	Maximum Monthly Allotment
1	$ 192
2	$ 352
3	$ 504
4	$ 640
5	$ 760
6	$ 913
7	$ 1,009
8	$ 1,153
Each additional person	$ 144

Benefit Calculation	Example
Multiply net income by 30%… (Round up)	$1,128.50 net monthly income x 0.3 = 338.55 (round up to $339)
Subtract 30% of net income from the maximum allotment for the household size…	$640 maximum allotment for 4-person household – $339 (30% of net income) = $301, SNAP Allotment for a full month

State	% of population receiving SNAP benefits
District of Columbia	22%
Mississippi	21%
New Mexico	22%
West Virginia	20%
Oregon	20%
Tennessee	20%
Louisiana	19%

County (or equivalent)	% of population receiving SNAP benefits
Kusilvak Census Area, Alaska	49%
Owsley County, Kentucky	49%
Oglala Lakota County, South Dakota	49%
Pemiscot County, Missouri	47%
Todd County, South Dakota	46%
Sioux County, North Dakota	45%
Dunklin County, Missouri	44%
East Carroll Parish, Louisiana	43%
Humphreys County, Mississippi	43%
Wolfe County, Kentucky	42%
Perry County, Alabama	41%
Phillips County, Arkansas	39%
Rolette County, North Dakota	39%
Ripley County, Missouri	39%
Ziebach County, South Dakota	39%

Born	September 30, 1965 (age 49)
Nationality	American
Institution	MIT
Field	Health economics
Alma mater	Harvard University (PhD, 1992) MIT (BSc, 1987)
Information at IDEAS/RePEc

	Republicans	Independents	Democrats
	%	%	%
2018 Jul 1-11	26	41	30
2018 Jun 1-13	27	43	29
2018 May 1-10	26	43	29
2018 Apr 2-11	24	45	29
2018 Mar 1-8	23	45	29
2018 Feb 1-10	28	42	27
2018 Jan 2-7	22	44	32
2017 Dec 4-11	25	46	27
2017 Nov 2-8	25	42	30
2017 Oct 5-11	24	42	31
2017 Sep 6-10	29	40	30
2017 Aug 2-6	28	41	28
2017 Jul 5-9	25	45	28
2017 Jun 7-11	26	42	30
2017 May 3-7	29	40	28
2017 Apr 5-9	25	44	28
2017 Mar 1-5	26	42	30
2017 Feb 1-5	31	37	31
2017 Jan 4-8	28	44	25
2016 Dec 7-11	28	39	29
2016 Nov 9-13	27	40	30
2016 Nov 1-6	27	36	31
2016 Oct 5-9	27	36	32
2016 Sep 14-18	27	40	32
2016 Sep 7-11	29	38	31
2016 Aug 3-7	27	38	31
2016 Jul 13-17	28	42	28
2016 Jun 14-23	28	39	31
2016 Jun 1-5	27	41	30
2016 May 18-22	27	45	28
2016 May 4-8	31	37	30
2016 Apr 6-10	25	44	31
2016 Mar 2-6	26	38	32
2016 Feb 3-7	30	37	30
2016 Jan 21-25	29	39	31
2016 Jan 6-10	26	44	29
2015 Dec 2-6	27	40	30
2015 Nov 4-8	28	39	30

	Republicans + Republican leaners	Democrats + Democratic leaners
	%	%
2018 Jul 1-11	40	44
2018 Jun 1-13	42	47
2018 May 1-10	44	44
2018 Apr 2-11	39	49
2018 Mar 1-8	38	48
2018 Feb 1-10	46	44
2018 Jan 2-7	35	50
2017 Dec 4-11	41	45
2017 Nov 2-8	39	46
2017 Oct 5-11	39	46
2017 Sep 6-10	45	47
2017 Aug 2-6	43	46
2017 Jul 5-9	40	48
2017 Jun 7-11	43	49
2017 May 3-7	45	44
2017 Apr 5-9	41	48
2017 Mar 9-29	38	47
2017 Mar 1-5	41	49
2017 Feb 1-5	43	48
2017 Jan 4-8	44	43
2016 Dec 7-11	41	42
2016 Nov 9-13	43	48
2016 Nov 1-6	43	46
2016 Oct 5-9	40	44
2016 Sep 14-18	44	49
2016 Sep 7-11	44	45
2016 Aug 3-7	41	48
2016 Jul 13-17	43	43
2016 Jun 14-23	42	48
2016 Jun 1-5	41	48
2016 May 18-22	47	46
2016 May 4-8	43	47
2016 Apr 6-10	41	49
2016 Mar 2-6	40	48
2016 Feb 3-7	43	46
2016 Jan 21-25	42	48
2016 Jan 6-10	44	45
2015 Dec 2-6	41	46

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