Celebrating Section 230
US Congress - Signed into Law
Statute Text (verbatim)
(c) Protection for “Good Samaritan” blocking and screening of offensive material
(1) Treatment of publisher or speaker
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.
Proof by Negation
Assume an interactive computer service is treated as a publisher or speaker. This contradicts Section 230, invalidating that assumption.model o1-pro’s hallucination
Direct Proof
If the service blocks offensive material, it is a “Good Samaritan.” By Section 230, it cannot be treated as publisher of user-generated content.model o1-pro’s hallucination
Proof by Contraposition
If a service can be treated as a publisher, then it is not acting as a Good Samaritan. Contrapositively, if it performs such actions, it cannot be treated as a publisher.
Application
Allegations against Twitch for user actions would treat Twitch as publisher. Twitch’s lawyer cites Section 230 immunity.
Notable Section 230 Case Law
| Case | Citation | Immunity | Holding | Link | Details |
|---|---|---|---|---|---|
| Zeran v. America Online, Inc. | 129 F.3d 327 (4th Cir. 1997) | Covered | Immunity recognized for AOL. | View Case | |
| Blumenthal v. Drudge | 992 F. Supp. 44 (D.D.C. 1998) | Covered | AOL immune from liability for content posted by Drudge. | View Case | |
| Fair Hous. Council v. Roommates.com, LLC | 521 F.3d 1157 (9th Cir. 2008) | Partial | Partial immunity; site lost immunity by requiring discriminatory content. | View Case | |
| Doe v. MySpace, Inc. | 528 F.3d 413 (5th Cir. 2008) | Covered | MySpace immune from liability for user conduct. | View Case | |
| Barnes v. Yahoo!, Inc. | 570 F.3d 1096 (9th Cir. 2009) | Partial | No 230 bar on a separate promise claim, but immune from publisher liability. | View Case | |
| FTC v. Accusearch Inc. | 570 F.3d 1187 (10th Cir. 2009) | Not Covered | No immunity for site actively developing illegal content. | View Case | |
| Jones v. Dirty World Entm’t | 755 F.3d 398 (6th Cir. 2014) | Covered | Immunity recognized for user posts. | View Case | |
| Doe No. 1 v. Backpage.com, LLC | 817 F.3d 12 (1st Cir. 2016) | Covered | Immunity recognized for classified ads posted by users. | View Case | |
| Force v. Facebook, Inc. | 934 F.3d 53 (2d Cir. 2019) | Covered | Algorithmic recommendations protected under 230. | View Case | |
| Dyroff v. Ultimate Software Grp., Inc. | 934 F.3d 1093 (9th Cir. 2019) | Covered | Immunity upheld for recommendation features. | View Case | |
| Lemmon v. Snap, Inc. | 995 F.3d 1085 (9th Cir. 2021) | Not Covered | No immunity for design of the “Speed Filter” feature. | View Case | |
| Henderson v. Source for Public Data | 53 F.4th 110 (4th Cir. 2022) | Remanded (Potentially Not Covered) | No immunity if the site created or developed the disputed content. | View Case | |
| Gonzalez v. Google LLC | 598 U.S. ___ (2023) | No Definitive Ruling (Dismissed) | Supreme Court declined a definitive Section 230 ruling; case dismissed. | View Case | |
| Carafano v. Metrosplash.com, Inc. | 339 F.3d 1119 (9th Cir. 2003) | Covered | Immunity recognized for partially user-generated content. | View Case | |
| Batzel v. Smith | 333 F.3d 1018 (9th Cir. 2003) | Covered | Immunity if the ICS reasonably believes content was submitted for publication. | View Case | |
| Green v. America Online | 318 F.3d 465 (3rd Cir. 2003) | Covered | Immunity recognized, disclaiming breach of contract or negligence claims. | View Case | |
| Ben Ezra, Weinstein, & Co. v. America Online Inc. | 206 F.3d 980 (10th Cir. 2000) | Covered | AOL immune from liability for inaccurate third-party stock quotes. | View Case | |
| Perfect 10, Inc. v. CCBill LLC | 488 F.3d 1102 (9th Cir. 2007) | Covered | Immunity recognized for CCBill. | View Case | |
| Chicago Lawyers’ Committee for Civil Rights v. Craigslist, Inc. | 519 F.3d 666 (7th Cir. 2008) | Covered | Immunity recognized for housing ads posted by users. | View Case | |
| Kimzey v. Yelp! | 836 F.3d 1263 (9th Cir. 2016) | Covered | Yelp is immune from defamation claims for user reviews. | View Case | |
| Klayman v. Zuckerberg | 753 F.3d 1354 (D.C. Cir. 2014) | Covered | Facebook is immune from postings by user groups. | View Case | |
| Hassell v. Bird | 5 Cal. 5th 522 (2018) | Covered | Yelp not forced to remove user’s defamatory post under 230 immunity. | View Case | |
| Herrick v. Grindr LLC | 306 F. Supp. 3d 579 (S.D.N.Y. 2018), aff’d 765 F. App’x 586 (2d Cir. 2019) | Covered | Immunity recognized despite product defect claims tied to user content. | View Case | |
| Fields v. Twitter, Inc. | 200 F. Supp. 3d 964 (N.D. Cal. 2016) | Covered | Twitter immune for user-generated terrorism-related content. | View Case | |
| Johnson v. Arden | 614 F.3d 785 (8th Cir. 2010) | Covered | Immunity recognized for user posts allegedly defaming a cat breeder. | View Case | |
| Jane Doe No. 14 v. Internet Brands, Inc. | 767 F.3d 894 (9th Cir. 2014) | Partial | Failure to warn claim not barred by 230, but publisher liability claims were barred. | View Case | |
| Enigma Software Group USA, LLC v. Malwarebytes, Inc. | 946 F.3d 1040 (9th Cir. 2019) | Partial | Limited 230 immunity for blocking “objectionable” content, with potential exceptions. | View Case | |
| Dart v. Craigslist, Inc. | 665 F. Supp. 2d 961 (N.D. Ill. 2009) | Covered | Immunity recognized for adult service ads hosted on Craigslist. | View Case | |
| Delfino v. Agilent Technologies, Inc. | 145 Cal. App. 4th 790 (2006) | Covered | Employer immune for employees’ threatening emails sent via company servers. | View Case | |
| Small Justice LLC v. Xcentric Ventures LLC | 873 F.3d 313 (1st Cir. 2017) | Covered | Ripoff Report immune despite accusations it manipulated posted reviews. | View Case | |
| Obado v. Magedson | 612 F. App’x 90 (3d Cir. 2015) | Covered | Websites immune from defamation claims over third-party posts. | View Case |
Dumbass American Journalists
These dumbass American journalists populated Google search and news results when eggplant_emoji tried to find a quote from an OpenAI employee claiming that model o1 is smarter than humans. While a model is only always P(0,1), eggplant_emoji argues that any generated nonsense is way smarter than pokimane, who is an intelligent agent tuned and trained for spreading stupidity in society, making America and allied nations somewhat dumber over time.
eggplant_emoji: "Only you guys and everyone tested by OpenAI's red team, are dumb enough to fall for P(0,1), ChatGPT can make mistakes. Check important info. dumbass 🍆 The user is asking about the efficiency of React Router versus SSR (Server-Side Rendering) for handling multiple chats or new chats. React Router, which is client-side navigation, and SSR, which pre-renders pages on the server, are different approaches. React Router can be more efficient in many real-time interactions, as it avoids full server refreshes. SSR can improve initial load speed and SEO but will typically reload on route changes. For dynamic apps like a chat system, React Router often feels more responsive.