Over the subsequent two decades, courts reviewing CDA 230 interpreted the
doctrine to shield online platforms from liability for a broad range of acts taken
by their users.8 In 1997, the Fourth Circuit in Zeran v. American Online
concluded that CDA 230 worked to shield platforms from both traditional
categories of publisher and distributor liability, rejecting an argument by the
plaintiff that the provision only worked to block publisher liability.9 In 2003,
the Ninth Circuit in Batzel v. Smith concluded that the phrase “interactive
computer services” in CDA 230 was not limited to services providing access
to the Internet as in Zeran and earlier cases but also included “any information
service or other systems” such as a listserv.10 Later cases also conﬁrmed that
users who were independent of an online service provider could invoke the
protection of CDA 230.11 In 2008, the Fifth Circuit in Doe v. MySpace found
Social_Media_and_Democracy