Narrative Opinion Summary
The case involves an appeal by a well-known actress against Matchmaker.com, Inc., Lycos, Inc., and Metrosplash.com, Inc., after an unauthorized and misleading dating profile was created using her identity on Matchmaker.com. The Ninth Circuit Court of Appeals reviewed whether the matchmaking service could be held liable for third-party content under 47 U.S.C. § 230(c)(1), which grants immunity to internet service providers from being treated as publishers of content provided by others. The court concluded that Matchmaker.com is statutorily immune, as it did not act as an information content provider. Despite the detailed questionnaire used for profile creation, the service merely facilitated user-generated content without developing or altering it. Carafano's claims of defamation, invasion of privacy, misappropriation of publicity rights, and negligence were dismissed due to the lack of evidence showing Matchmaker's active involvement in content creation. The district court's summary judgment in favor of the defendants was affirmed, with the court emphasizing the legislative intent to protect service providers and promote free expression on the Internet by avoiding undue liability for user-generated content.
Legal Issues Addressed
Application of Negligence Claimssubscribe to see similar legal issues
Application: The negligence claim against Matchmaker was rejected as the service did not manipulate or contribute to the creation of the misleading profile content.
Reasoning: Appellants' negligence claim, which alleges manipulation of content by others, does not alter this conclusion, as it would improperly attribute liability to Matchmaker for content it did not create.
Definition of Interactive Computer Servicesubscribe to see similar legal issues
Application: The court found that Matchmaker.com qualifies as an interactive computer service, thus eligible for § 230(c) immunity, as it did not create or develop the content in question.
Reasoning: Courts have interpreted § 230(c) to offer robust immunity, broadly defining 'interactive computer service' while narrowly defining 'information content provider.' A service qualifies for immunity as long as it does not also act as an information content provider regarding the material in question.
Immunity under 47 U.S.C. § 230(c)(1)subscribe to see similar legal issues
Application: The court determined that Matchmaker.com is protected from liability as an internet service provider for third-party content, as it did not act as an information content provider regarding the profile.
Reasoning: The Court determined that Matchmaker.com is statutorily immune from liability under 47 U.S.C. § 230(c)(1), which protects internet service providers from being treated as publishers of third-party content.
Role of User-Generated Contentsubscribe to see similar legal issues
Application: Despite the structured nature of the questionnaire, Matchmaker.com was not deemed to have contributed to the creation or development of the harmful content.
Reasoning: Matchmaker's immunity remains intact even if some content arises from user responses to a questionnaire, as it does not create or develop the profile information until users actively choose options and provide text.