Section 230 Immunizes Links to Defamatory Third Party Content–Directory Assistants v. Supermedia

17 08 2012

By Eric Goldman

Directory Assistants, Inc. v. Supermedia, LLC, 2012 WL 3329615 (E.D. Va. May 30, 2012)

Unknown parties posted negative reviews of Directory Assistants to various review sites, including,,,, and Directory Assistants claims the reviews are defamatory. Supermedia, which apparently partially competes with Directory Assistants, allegedly sent prospective customers emails with links to those reviews. Directory Assistants sued Supermedia for circulating those links.

In this ruling, the court dismisses (on a 12(b)(6) motion to dismiss) Directory Assistants’ suit against Supermedia on 47 USC 230 grounds.


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