Section 230 Applies to Amazon Book Reviews–Joseph v. Amazon

1 12 2014


As I’ve recently mentioned, many recent Section 230 rulings involve pro se plaintiffs because most lawyers have wizened up to Section 230?s immunity. In this case, Dr. Joseph, a pro se plaintiff, brings a long list of gripes about Amazon to court. I’ll focus just on the part where he “alleges that Amazon unlawfully published defamatory anonymous reviews of Plaintiff’s books (and Plaintiff) on its website.”

The court quickly runs through Amazon’s eligibility for Section 230. Other cases have held that Amazon is a provider of interactive computer services (Corbis, Schneider), Dr. Joseph expressly alleges that Amazon “published” the reviews, and the reviews came from third parties (but see below). Thus, Amazon established its prima facie Section 230 immunity.


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