In February 1996, faced with increasing public concern about the
availability of pornography on the internet, as well as recent
court decisions that seem to deter efforts to filter out such
content, Congress enacted the Communications Decency Act
("CDA"). As part of the CDA, Congress granted
immunity to internet service providers from liability for actions
they took to help users block online content that a user found to
be offensive or objectionable. Congress further declared its
goals in enacting the CDA, and its immunity provision, were
"to encourage the development of technologies which maximize
user control;" "to empower parents to restrict their
children's access to objectionable or inappropriate online
content;" and "to preserve the vibrant and competitive
free market that presently exists for the internet and other
interactive computer services." In 2009, the Ninth
Circuit decided the case, Zango, Inc. v. Kaspersky Lab,
Inc., 568 F.3d 1169, which held that
