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Technology

May 15, 2026

Section 230 is starting to show its cracks

While Doe v. Meta follows existing Section 230 law, its concurrences signal rising judicial pressure to narrow platform immunity for algorithm-driven recommendations--potentially reshaping social media law and inviting Supreme Court review.

Joanna Rosen Forster

Partner
Crowell & Moring LLP

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Warrington Parker

Partner
Crowell & Moring LLP

Phone: (415) 986-2800

Email: wparker@crowell.com

Harvard Univ Law School; Cambridge MA

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Jacob Canter

Counsel
Crowell & Moring LLP

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Joachim B. Steinberg

Counsel
Crowell & Moring LLP

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Section 230 is starting to show its cracks
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The decision in Doe v. Meta Platforms, Inc., 24-1672 (9th Cir.) appears to be a routine application of Section 230 immunity under well-settled circuit precedent. But two concurrences reflect judicial willingness to reconsider a key term in Section 230 that could reshape modern social media law. The decision and concurrences are less a statement of settled law than a snapshot of a doctrine in flux.

Background on Section 230

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