Despite continued scrutiny over the legal immunity
online providers enjoy under Section 230 of the Communications
Decency Act (CDA), online platforms continue to successfully invoke
its protections. This is illustrated by three recent decisions in
which courts dismissed claims that sought to impose liability on
providers for hosting or restricting access to user content and for
providing a much-discussed social media app filter.
In one case, a California district court dismissed a negligence
claim against online real estate database Zillow over a fraudulent
posting, holding that any allegation of a duty to monitor new users
and prevent false listing information inherently derives from
Zillow's status as a publisher and is therefore barred by the
CDA. (924 Bel Air Road LLC v. Zillow Group
Inc., No. 19-01368 (C.D. Cal. Feb. 18, 2020)). In the
second, the Ninth Circuit, in an important ruling, affirmed the
dismissal of claims against YouTube for violations of the
