  One might be inclined to argue that since FN deliberately promotes erroneous and inaccurate information as truthful content, it should be more closely regulated by governmental agencies. But as Lipinski (2018, 69) points out, “while all Fake News possesses an element of untruth, not all Fake News is defamatory.” He goes on to note that in the U.S., the purveyor of non-defamatory FN is protected by the First Amendment; so there is no legal recourse against the “speaker” of non-defamatory FN or against the media outlets that post it. Thus, Lipinski’s description of the law could be interpreted to suggest that SECs, along with social media sites, should be exonerated from any legal liability when it comes to the dissemination of FN. Yet, even if social media sites continue to permit the posting of FN on their platforms, we can still ask whether SECs might be held to a higher standard, given their privileged role as gatekeepers of knowledge on the Web to ensure that search engine users users are directed to information that is “accurate”.  