Doe v. Placing Real-Life Liability Back Where It Belongs in a Virtual World

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Volume 9, Issue 1 (Jun 2012)

This Recent Development examines the implications of Doe v., a case decided by the U.S. District Court for the Northern District of Ohio in August 2007, on jurisprudence surrounding website immunity from liability as provided by the Communications Decency Act of 1996. Specifically, this Recent Development compares the reasoning used in with that used in Fair Housing Council v., a May 2007 case decided by the Ninth Circuit Court of Appeals. The author asserts that the decision broke with the will of Congress as expressed in the Communications Decency Act and with federal court precedent, as it opened up a more narrow view of immunity under the Act. is a step back towards clarity and a more equitable distribution of liability for user-supplied online content.

Jonathan R. Burns, Recent Development, Doe v. Placing Real-Life Liability Back Where It Belongs in a Virtual World, 9 N.C. J.L. & Tech. 69 (2007), available at

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