Doe v. America Online, Inc. This lawsuit was commenced in 1997 and accused AOL of facilitating the sale of pornographic materials by members. The lawsuit was filed in the circuit court for West Palm Beach, Florida. AOL filed a motion to dismiss arguing that under Section 230 of the Telecommunications Act of 1996, AOL could not be held responsible for the communications of a former member. The court granted AOL's motion and dismissed the case with prejudice. This case marked only the second time that the section 230 defense had been successfully invoked (the other instance being Zeran v. America Online, Inc.).
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