The Never-Ending Limits of ? 230: Extending ISP Immunity to the Sexual Exploitation of Children by Katy Noeth

In 2006, the U.S. District Court for the Eastern District of Texas extended civil liability to Yahoo! under ? 230 of the Communications Decency Act so that it could not be sued for knowingly profiting from a Web site where members exchanged sexually explicit pictures of minors. The court found that the reasoning of the seminal ? 230 case, Zeran v. AOL, was analogous and that policy considerations mandated its holding.

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