A recent case in which the violent history of the user of an Internet dating site was not revealed to a potential match, resulting in her harm, has caused the Ninth Circuit to make significant changes to use of Section 230. The Ninth Circuit recently limited the ability of websites and online services to use Section 230 of the CDA to shield themselves from lawsuits that arise out of offline conduct of their users. The CDA releases federal liability for information originating from use of an interactive computer service or anyone who is responsible for the creation of development of information, such as micro-blogging sites, user-generated video sites, consumer-review sites and spam reporting sites.

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