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

Human-scored winner

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

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CaseCitationYearImmunityHoldingLinkDetails
Barnes v. Yahoo!, Inc.570 F.3d 1096 (9th Cir. 2009)N/APartialNo 230 bar on a separate promise claim, but immune from publisher liability.View Case
Batzel v. Smith333 F.3d 1018 (9th Cir. 2003)N/ACoveredImmunity if the ICS reasonably believes content was submitted for publication.View Case
Ben Ezra, Weinstein, & Co. v. America Online Inc.206 F.3d 980 (10th Cir. 2000)N/ACoveredAOL immune from liability for inaccurate third-party stock quotes.View Case
Blumenthal v. Drudge992 F. Supp. 44 (D.D.C. 1998)N/ACoveredAOL immune from liability for content posted by Drudge.View Case
Carafano v. Metrosplash.com, Inc.339 F.3d 1119 (9th Cir. 2003)N/ACoveredImmunity recognized for partially user-generated content.View Case
Chicago Lawyers’ Committee for Civil Rights v. Craigslist, Inc.519 F.3d 666 (7th Cir. 2008)N/ACoveredImmunity recognized for housing ads posted by users.View Case
Dart v. Craigslist, Inc.665 F. Supp. 2d 961 (N.D. Ill. 2009)N/ACoveredImmunity recognized for adult service ads hosted on Craigslist.View Case
Delfino v. Agilent Technologies, Inc.145 Cal. App. 4th 790 (2006)2006CoveredEmployer immune for employees’ threatening emails sent via company servers.View Case
Doe No. 1 v. Backpage.com, LLC817 F.3d 12 (1st Cir. 2016)N/ACoveredImmunity recognized for classified ads posted by users.View Case
Doe v. MySpace, Inc.528 F.3d 413 (5th Cir. 2008)N/ACoveredMySpace immune from liability for user conduct.View Case
Dyroff v. Ultimate Software Grp., Inc.934 F.3d 1093 (9th Cir. 2019)N/ACoveredImmunity upheld for recommendation features.View Case
Enigma Software Group USA, LLC v. Malwarebytes, Inc.946 F.3d 1040 (9th Cir. 2019)N/APartialLimited 230 immunity for blocking “objectionable” content, with potential exceptions.View Case
Fair Hous. Council v. Roommates.com, LLC521 F.3d 1157 (9th Cir. 2008)N/APartialPartial immunity; site lost immunity by requiring discriminatory content.View Case
Fields v. Twitter, Inc.200 F. Supp. 3d 964 (N.D. Cal. 2016)N/ACoveredTwitter immune for user-generated terrorism-related content.View Case
Force v. Facebook, Inc.934 F.3d 53 (2d Cir. 2019)N/ACoveredAlgorithmic recommendations protected under 230.View Case
FTC v. Accusearch Inc.570 F.3d 1187 (10th Cir. 2009)N/ANot CoveredNo immunity for site actively developing illegal content.View Case
Gonzalez v. Google LLC598 U.S. ___ (2023)2023No Definitive Ruling (Dismissed)Supreme Court declined a definitive Section 230 ruling; case dismissed.View Case
Green v. America Online318 F.3d 465 (3rd Cir. 2003)N/ACoveredImmunity recognized, disclaiming breach of contract or negligence claims.View Case
Hassell v. Bird5 Cal. 5th 522 (2018)2018CoveredYelp not forced to remove user’s defamatory post under 230 immunity.View Case
Henderson v. Source for Public Data53 F.4th 110 (4th Cir. 2022)N/ARemanded (Potentially Not Covered)No immunity if the site created or developed the disputed content.View Case
Herrick v. Grindr LLC306 F. Supp. 3d 579 (S.D.N.Y. 2018), aff’d 765 F. App’x 586 (2d Cir. 2019)N/ACoveredImmunity recognized despite product defect claims tied to user content.View Case
Jane Doe No. 14 v. Internet Brands, Inc.767 F.3d 894 (9th Cir. 2014)N/APartialFailure to warn claim not barred by 230, but publisher liability claims were barred.View Case
Johnson v. Arden614 F.3d 785 (8th Cir. 2010)N/ACoveredImmunity recognized for user posts allegedly defaming a cat breeder.View Case
Jones v. Dirty World Entm’t755 F.3d 398 (6th Cir. 2014)N/ACoveredImmunity recognized for user posts.View Case
Kimzey v. Yelp!836 F.3d 1263 (9th Cir. 2016)N/ACoveredYelp is immune from defamation claims for user reviews.View Case
Klayman v. Zuckerberg753 F.3d 1354 (D.C. Cir. 2014)N/ACoveredFacebook is immune from postings by user groups.View Case
Lemmon v. Snap, Inc.995 F.3d 1085 (9th Cir. 2021)N/ANot CoveredNo immunity for design of the “Speed Filter” feature.View Case
Obado v. Magedson612 F. App’x 90 (3d Cir. 2015)N/ACoveredWebsites immune from defamation claims over third-party posts.View Case
Perfect 10, Inc. v. CCBill LLC488 F.3d 1102 (9th Cir. 2007)N/ACoveredImmunity recognized for CCBill.View Case
Small Justice LLC v. Xcentric Ventures LLC873 F.3d 313 (1st Cir. 2017)N/ACoveredRipoff Report immune despite accusations it manipulated posted reviews.View Case
Zeran v. America Online, Inc.129 F.3d 327 (4th Cir. 1997)N/ACoveredImmunity recognized for AOL.View Case

Thank you Sam Atman et al. for creating the 21st Century's Turing Test! ChatGPT can make mistakes. Check important info. Despite British Mark Leon's constant homophobism, another homosexual invents what I term the Turing Test 2.0.

American journalism

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), if you can't outsmart P(0,1), such as if you're a heavy Twitch user such as Mark Leon or his entire Twitch gang, who suffers from deep psychological problems, please leave me alone!

Model o1 Pro Journalists

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 for real-time interactions, while SSR can improve initial load speed and SEO but typically reloads on route changes. For dynamic apps like a chat system, React Router often feels more responsive.