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ARTICLE · 26 JULY 2019

D.C. Circuit Holds That Section 230 Locks Out Locksmiths

Morrison Foerster
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As we noted in our recent post on the Second Circuit case Herrick v. Grindr, LLC, Section 230 of the Communications Decency Act (CDA)

United StatesMedia, Telecoms, IT, Entertainment

As we noted in our recent post on the Second Circuit case Herrick v. Grindr, LLC, Section 230 of the Communications Decency Act (CDA) continues to provide immunity to online intermediaries from liability for user content, despite pressure from courts and legislatures seeking to chip away at this safe harbor. The Federal Circuit case Marshall's Locksmith Service Inc. v. Google, LLC serves as another example of Section 230's resiliency.

In Marshall's Locksmith, the Federal Circuit affirmed the dismissal of claims brought by 14 locksmith companies against search engine operators Google, Microsoft and Yahoo! for allegedly conspiring to allow "scam locksmiths" to inundate the online search results page in order to extract additional advertising revenue.

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Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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