D.C. Circuit Holds Locksmiths Cannot Unlock Google's § 230 Protection

Section 230 immunity (47 U.S.C. § 230 (c)(1)) protects internet platforms, such as Google or Twitter, from culpability for the information they publish. Section 230 states that "[n]o provider or user of an interactive computer service shall be treated as the publisher or speaker of information provided by another information content provider."

In Marshall's Locksmith Service, Inc. v. Google, LLC, – – – F.3d – – – , 2019 WL 2398008 (D.C. Cir. June 7, 2019), the United States Court of Appeals for the D.C. Circuit considered yet another failed attack on Google's § 230 immunity. Although the Court rejected several arguments seeking to impose liability on Google for its publication of false information provided by third parties, the Court recognized one theory that might prove viable to establish liability in future cases.