Starr™ v. Google LLC, 2026 WL 1603313 (W.D. Tex. June 3, 2026) The Western District of Texas granted Google’s motion […]
After the Ninth Circuit carved out ‘promise-based claims’ from Section 230 immunity, the district court grants summary judgment for Snap anyway, finding that content moderation statements are too vague to be actionable misrepresentations.
A federal district court dismissed defamation claims against WorldStarHipHop under Section 230, holding that downloading a third-party video and adding a new caption and tags constituted only ‘minor, paratextual modifications’ insufficient to strip platform immunity.
A federal court denied Academia.edu’s Section 230 defense and rejected all four attempts to compel arbitration in a class action alleging the platform used professors’ names in commercial advertisements without consent.
The Ninth Circuit affirmed dismissal of claims by Rohingya plaintiffs alleging Facebook’s algorithm amplified anti-Rohingya violence in Myanmar, holding that Section 230 immunizes Meta from liability for algorithmically recommending third-party content — though two concurring opinions urged the court to reconsider its broad reading of Section 230.
The Ninth Circuit ruled that Section 230 bars claims by Rohingya plaintiffs alleging that Facebook’s algorithmic design fueled genocide in Myanmar, but two concurrences urged the court to reconsider the sweeping scope of the immunity.
Two parallel N.D. Cal. rulings dismiss all claims—First Amendment, conspiracy, contract, and emotional distress—against Meta for suspending user accounts, holding that Section 230 immunizes platforms’ editorial decisions even when alleged to target political viewpoints.
In a consolidated order resolving three writ petitions, the Nevada Supreme Court applied its earlier TikTok and Snap decisions to reject Meta’s challenge to the State’s deceptive-trade-practices, products liability, negligence, and unjust enrichment claims over Messenger, Facebook, and Instagram — holding that personal jurisdiction was properly exercised and that neither Section 230 nor the First Amendment shields Meta from state-law claims aimed at platform design rather than third-party content.
A federal magistrate judge held that Section 230 immunizes X (formerly Twitter) from a premium subscriber’s claims that the platform amplified harmful content via its recommendation algorithm and suppressed the subscriber’s own posts, rejecting the argument that algorithmic curation falls outside Section 230’s protections.
Judge Donald Nugent dismissed all claims — negligence, strict liability, concealment, and misrepresentation — against Discord brought on behalf of a minor sexually exploited by an adult user, holding that the plaintiff’s “defective design” theory was a repackaged demand that Discord moderate or block third-party communications, which Section 230 forecloses.
In a landmark ruling, the Massachusetts Supreme Judicial Court held that Section 230 of the Communications Decency Act does not immunize Meta from state-law claims that Instagram was deliberately designed to addict children — distinguishing platform design choices from third-party content moderation.
Chief Judge Seeborg denied Meta’s motion to dismiss claims by investors who lost more than $300 million to a Chinese penny-stock scam advertised on Facebook and Instagram, holding that Meta’s generative-AI advertising tool ‘Advantage+ Creative’ — which actually produced some of the ad text and imagery — raised a plausible factual dispute on whether Meta materially contributed to the offending content and thus lost Section 230 immunity.
A Fayette County, Pennsylvania trial court refused to dismiss a wrongful-death suit against FareHarbor — the platform that managed a rafting outfitter’s website — holding that Section 230 does not immunize a defendant alleged to have helped develop the offending content.
Chief Judge Bashant’s amended summary-judgment order in The Upper Deck Co. v. Pixels.com draws a clean line through Section 230 for print-on-demand platforms: when Pixels acts as a website operator displaying and indexing user-uploaded images, Section 230 immunizes it; when Pixels acts as the manufacturer, seller, and shipper of physical prints containing those same images, Section 230 does not.
On the second trip up, the Ninth Circuit vacated most of the district court’s preliminary injunction against California’s Age-Appropriate Design Code Act — but kept the data-use and dark-patterns restrictions enjoined on vagueness grounds, leaving the statute partially in force.
An unpublished Ninth Circuit memorandum reverses the dismissal of product-liability, negligence, and NIED claims brought after two teenagers ingested sodium nitrite purchased from Amazon — but leaves intact the district court’s holding that Section 230 bars the part of the case premised on Amazon’s removal of warning reviews.
The Wisconsin Supreme Court joined a near-unanimous national consensus that an electronic service provider that scans user accounts for child sexual abuse material and reports its findings does so as a private actor, not a government agent — and that neither Section 230 nor 18 U.S.C. § 2258A converts that activity into state action.
Reviving claims against the online firearms marketplace Armslist, the First Circuit held that 16,000 New Hampshire firearm listings per year — viewed together with the site’s geographic-listing design and the advertising revenue those listings generated — were enough to make a prima facie case of purposeful availment. Section 230 was raised but not decided and remains open on remand.
Iowa’s Attorney General sued TikTok over what she alleges are deceptive ’12+’ age ratings in the Apple App Store. A unanimous Iowa Supreme Court held that TikTok’s contractual relationships with hundreds of thousands of Iowa users, plus its targeted advertising and Iowa-specific data collection, were more than enough to support specific personal jurisdiction.