Big Tech Litigation Tracker

Status of every row is stated as of . Next scheduled review . Legislative status changes constantly; re-verify any row against its linked source before citing it.

Thirty-nine lawsuits against the major technology platforms over harm caused by content their recommender systems promoted — terrorism recruitment, child sexual abuse material, trafficking advertisements, self-harm challenges, illegal drug sales, radicalisation — together with the state attorney general enforcement actions that grew out of the same conduct. Filter by who sued, or by how the court ruled on Section 230, and open any row for the full ruling and its sourcing.1

Sort the §230 Result column and the argument of this site appears without commentary: platforms almost never lose to the people they harmed, and almost always lose to a state attorney general pleading the same facts. That gap, and the six rows that are not yet adequately sourced, are explained beneath the table: what the pattern shows, how to read it, and what it covers and what it does not.

Click a column heading to sort. Filter by Section 230 result to see the pattern. Use the arrow at the end of a row to read the full ruling, status and sourcing.

Case Defendant §230 Result Claim Type Court Filed Details
Force v. Facebook, Inc. Meta Immunity granted A - Promoted illegal content U.S. Court of Appeals, 2d Cir. 2016
Defendants
Meta (Facebook)
Court
U.S. Court of Appeals, 2d Cir.
Docket / Citation
934 F.3d 53 (2d Cir. 2019); cert. denied 140 S. Ct. 2761 (2020)
Filed
2016
Who Brought It
Victims and estates of Hamas attacks in Israel
Harm Alleged
Terrorism - Hamas recruitment/incitement content, algorithmically suggested to users
Theory Pleaded
Anti-Terrorism Act (ATA) civil liability; aiding and abetting
Section 230 Ruling
IMMUNITY GRANTED. Majority held friend/content suggestion algorithms are neutral publishing tools. Chief Judge Katzmann dissented in part, arguing algorithmic recommendation is Facebook's own conduct, not third-party publishing.
Status
Closed. Dismissal affirmed; Supreme Court denied cert. May 2020.
Why It Matters
The Katzmann partial dissent is the origin point of the modern 'algorithm as first-party speech' argument later adopted by the 3d Cir. in Anderson v. TikTok.
Sourcing
Appellate opinion
Gonzalez v. Google LLC Google / Alphabet Not reached A - Promoted illegal content U.S. Supreme Court 2016
Defendants
Google / Alphabet (YouTube)
Court
U.S. Supreme Court
Docket / Citation
598 U.S. 617 (2023) (per curiam)
Filed
2016
Who Brought It
Family/estate of Nohemi Gonzalez, killed in 2015 ISIS Paris attacks
Harm Alleged
Terrorism - ISIS recruitment videos recommended by YouTube's algorithm
Theory Pleaded
ATA aiding and abetting; direct/secondary liability for algorithmic recommendation
Section 230 Ruling
NOT REACHED. The Court expressly declined to address Section 230, vacating and remanding in light of Taamneh because the underlying ATA claim failed.
Status
Closed on remand. The single best chance to get a Supreme Court ruling on algorithmic recommendation under 230 - and the Court ducked it.
Why It Matters
The Supreme Court has still never ruled on whether Section 230 covers algorithmic recommendations. This is the central unresolved question and the strongest argument that only Congress can fix it.
Sourcing
Supreme Court opinion
Twitter, Inc. v. Taamneh Multiple platforms Not reached A - Promoted illegal content U.S. Supreme Court 2017
Defendants
Twitter/X, Google (YouTube), Meta (Facebook)
Court
U.S. Supreme Court
Docket / Citation
598 U.S. 471 (2023)
Filed
2017
Who Brought It
Family of Nawras Alassaf, killed in 2017 Reina nightclub attack, Istanbul
Harm Alleged
Terrorism - ISIS content hosted and recommended across platforms
Theory Pleaded
JASTA / ATA Sec. 2333(d)(2) aiding and abetting
Section 230 Ruling
NOT REACHED. Decided purely on aiding-and-abetting elements. Unanimous: plaintiffs did not plausibly allege knowing, substantial assistance to the specific attack. The Court noted the algorithm treated all content alike regardless of nature.
Status
Closed. 9th Cir. reversed.
Why It Matters
Effectively closed the terrorism-statute route to platform liability without touching 230 - meaning victims lost on causation grounds before 230 was even tested.
Sourcing
Supreme Court opinion
Fields v. Twitter, Inc. Twitter / X Not reached A - Promoted illegal content U.S. Court of Appeals, 9th Cir. 2016
Defendants
Twitter/X
Court
U.S. Court of Appeals, 9th Cir.
Docket / Citation
881 F.3d 739 (9th Cir. 2018)
Filed
2016
Who Brought It
Widows/estates of two U.S. contractors killed in Jordan
Harm Alleged
Terrorism - ISIS accounts and content
Theory Pleaded
ATA direct liability
Section 230 Ruling
NOT REACHED. Dismissed for failure to plead ATA proximate causation.
Status
Closed.
Why It Matters
Part of the pattern: courts dispose of content-harm suits on causation, so the 230 question never gets decided on the merits.
Sourcing
Appellate opinion
Crosby v. Twitter, Inc. Multiple platforms Not reached A - Promoted illegal content U.S. Court of Appeals, 6th Cir. 2016
Defendants
Twitter/X, Google (YouTube), Meta (Facebook)
Court
U.S. Court of Appeals, 6th Cir.
Docket / Citation
921 F.3d 617 (6th Cir. 2019)
Filed
2016
Who Brought It
Survivors and families, 2016 Pulse nightclub shooting, Orlando
Harm Alleged
Terrorism - ISIS radicalization content
Theory Pleaded
ATA aiding and abetting
Section 230 Ruling
NOT REACHED. Dismissed on ATA proximate cause.
Status
Closed.
Why It Matters
Same causation barrier as Fields.
Sourcing
Appellate opinion
Colon v. Twitter, Inc. Multiple platforms Not reached A - Promoted illegal content U.S. Court of Appeals, 11th Cir. 2018
Defendants
Twitter/X, Google (YouTube), Meta (Facebook)
Court
U.S. Court of Appeals, 11th Cir.
Docket / Citation
14 F.4th 1213 (11th Cir. 2021)
Filed
2018
Who Brought It
Survivors and families, Pulse nightclub shooting
Harm Alleged
Terrorism - ISIS radicalization content
Theory Pleaded
ATA aiding and abetting
Section 230 Ruling
NOT REACHED. Dismissed on ATA proximate cause.
Status
Closed.
Why It Matters
Third circuit to reach the same result on causation.
Sourcing
Appellate opinion
Retana v. Twitter, Inc. Multiple platforms Not reached A - Promoted illegal content U.S. Court of Appeals, 8th Cir. 2018
Defendants
Twitter/X, Google (YouTube), Meta (Facebook)
Court
U.S. Court of Appeals, 8th Cir.
Docket / Citation
1 F.4th 638 (8th Cir. 2021)
Filed
2018
Who Brought It
Families of Dallas police officers killed in 2016 ambush
Harm Alleged
Terrorism/extremism - Hamas and extremist content
Theory Pleaded
ATA aiding and abetting
Section 230 Ruling
NOT REACHED. Dismissed on ATA elements.
Status
Closed.
Why It Matters
Same pattern.
Sourcing
Appellate opinion
Clayborn v. Twitter, Inc. Multiple platforms Not reached A - Promoted illegal content N.D. Cal. 2017
Defendants
Twitter/X, Google (YouTube), Meta (Facebook)
Court
N.D. Cal.
Docket / Citation
No. 17-cv-06894 (N.D. Cal. 2018)
Filed
2017
Who Brought It
Families of victims, 2015 San Bernardino attack
Harm Alleged
Terrorism - ISIS content
Theory Pleaded
ATA aiding and abetting
Section 230 Ruling
NOT REACHED. Dismissed on ATA elements.
Status
Closed.
Why It Matters
Same pattern.
Sourcing
Secondary reporting only
Anderson v. TikTok, Inc. (Nylah Anderson / 'Blackout Challenge') TikTok / ByteDance Immunity denied A - Promoted illegal content U.S. Court of Appeals, 3d Cir.; remanded to E.D. Pa. 2022
Defendants
TikTok Inc., ByteDance Ltd.
Court
U.S. Court of Appeals, 3d Cir.; remanded to E.D. Pa.
Docket / Citation
116 F.4th 180 (3d Cir. Aug. 27, 2024); No. 22-3061
Filed
2022
Who Brought It
Mother (Tawainna Anderson) of 10-year-old who died attempting the challenge
Harm Alleged
Self-harm/asphyxiation challenge video, served to a 10-year-old via the For You Page algorithm
Theory Pleaded
Products liability, negligent design, wrongful death
Section 230 Ruling
IMMUNITY DENIED - LANDMARK. Held TikTok's algorithmic curation of a For You Page is TikTok's OWN first-party expressive activity, not 'information provided by another,' so Section 230(c)(1) does not apply. Reversed in part, vacated in part, remanded.
Status
Remanded to E.D. Pa. for further proceedings; ongoing as of Sep. 2026.
Why It Matters
THE most important case for the argument that Section 230 was never meant to cover recommender systems. Creates a circuit split with the 2d, 4th, and 9th Circuits - the classic predicate for Supreme Court review or congressional action.
Sourcing
Appellate opinion (precedential)
M.P. v. Meta Platforms, Inc. Meta Immunity granted A - Promoted illegal content U.S. Court of Appeals, 4th Cir. 2022
Defendants
Meta (Facebook)
Court
U.S. Court of Appeals, 4th Cir.
Docket / Citation
No. 23-1880 (4th Cir. Feb. 2025); cert. denied 2025
Filed
2022
Who Brought It
Daughter of Rev. Clementa Pinckney, killed in 2015 Emanuel AME Church massacre
Harm Alleged
White-supremacist radicalization content recommended to shooter Dylann Roof
Theory Pleaded
Strict products liability, negligence, NIED; 42 U.S.C. Sec. 1985(3)
Section 230 Ruling
IMMUNITY GRANTED. Divided panel held state tort claims treated Facebook as publisher of third-party content; also found no plausible proximate cause under S.C. law. Dissent argued recommending groups/users is Facebook's own speech.
Status
Closed. Supreme Court declined review in 2025.
Why It Matters
Direct conflict with Anderson v. TikTok on identical facts-pattern (algorithmic radicalization). The dissent is quotable advocacy material.
Sourcing
Appellate opinion
Patterson v. Meta Platforms, Inc. (Buffalo / Tops Market massacre) Multiple platforms Immunity granted A - Promoted illegal content N.Y. Sup. Ct., Erie Cty.; N.Y. App. Div., 4th Dept. 2023
Defendants
Meta, Alphabet/Google (YouTube), Reddit, Amazon (Twitch), Discord, Snap, 4chan and others
Court
N.Y. Sup. Ct., Erie Cty.; N.Y. App. Div., 4th Dept.
Docket / Citation
App. Div. 4th Dept. decision July 25, 2025
Filed
July 2023
Who Brought It
Survivors, victims' families, employees and customers present at the 2022 Buffalo shooting
Harm Alleged
White-supremacist radicalization content; livestream of the attack
Theory Pleaded
Products liability - platforms defectively designed to addict and radicalize (Gendron)
Section 230 Ruling
IMMUNITY GRANTED ON APPEAL. Trial court (Mar. 2024, Judge Feroleto) had allowed claims against YouTube and Reddit to proceed; the Fourth Department REVERSED on July 25, 2025, holding Section 230 immunity applies.
Status
Reversed and dismissed at the intermediate appellate level. Further appeal to the N.Y. Court of Appeals not confirmed in sources reviewed - VERIFY before citing as final.
Why It Matters
Shows how quickly a trial-level win for victims evaporates on appeal. Also the broadest defendant list of any private suit - Meta, Google, Amazon, Reddit, Discord together.
Sourcing
Secondary reporting only - appellate opinion not pulled
Doe #1 v. Twitter, Inc. / Doe v. X Corp. Twitter / X Partial denial A - Promoted illegal content U.S. Court of Appeals, 9th Cir.; N.D. Cal. 2021
Defendants
Twitter / X Corp.
Court
U.S. Court of Appeals, 9th Cir.; N.D. Cal.
Docket / Citation
9th Cir. opinion Aug. 1, 2025; cert. denied May 18, 2026 (No. 25-949)
Filed
2021
Who Brought It
Two boys trafficked as teens; CSAM of them posted to Twitter
Harm Alleged
CSAM - trafficking material left up ~9 days after report, reaching 167,000+ views
Theory Pleaded
18 U.S.C. Sec. 1591 beneficiary liability (FOSTA carve-out); products liability; negligence per se under 18 U.S.C. Sec. 2258A (failure to report to NCMEC)
Section 230 Ruling
MIXED - PARTIAL DENIAL. Section 230 barred the Sec. 1591 'knowingly benefits' claim and the product-defect theories (leaving flagged posts up; search amplification). BUT the panel REVIVED a negligence-per-se claim for failure to promptly report known CSAM to NCMEC.
Status
Cert denied May 18, 2026, leaving the split decision standing. Revived claims proceeding below.
Why It Matters
Demonstrates that FOSTA - Congress's one narrow 230 carve-out - largely failed to help actual CSAM victims. Strong evidence that piecemeal carve-outs don't work and full repeal/rewrite is needed.
Sourcing
Appellate opinion + Supreme Court docket
Doe v. Reddit, Inc. Reddit Immunity granted A - Promoted illegal content U.S. Court of Appeals, 9th Cir. 2021
Defendants
Reddit
Court
U.S. Court of Appeals, 9th Cir.
Docket / Citation
51 F.4th 1137 (9th Cir. 2022); cert. denied 2023
Filed
2021
Who Brought It
Minor CSAM victims and their parents
Harm Alleged
CSAM posted and monetized in subreddits
Theory Pleaded
18 U.S.C. Sec. 1591 beneficiary liability via FOSTA carve-out
Section 230 Ruling
IMMUNITY GRANTED. Held the FOSTA carve-out requires the platform's OWN actual knowledge of participation in the specific trafficking venture - constructive knowledge insufficient. Dismissal affirmed.
Status
Closed. Cert denied 2023.
Why It Matters
The single clearest proof that FOSTA-SESTA is functionally toothless: the carve-out's knowledge standard is set so high that almost no victim can meet it.
Sourcing
Appellate opinion
In re Facebook, Inc. (Texas trafficking cases) Meta Partial denial A - Promoted illegal content Supreme Court of Texas 2018
Defendants
Meta (Facebook, Instagram)
Court
Supreme Court of Texas
Docket / Citation
625 S.W.3d 80 (Tex. 2021), No. 20-0434; cert. denied 2022
Filed
2018
Who Brought It
Three women trafficked as minors after being recruited via Facebook
Harm Alleged
Sex trafficking - recruitment by traffickers using the platform
Theory Pleaded
Common-law negligence/products liability AND Tex. Civ. Prac. & Rem. Code ch. 98 statutory trafficking claim
Section 230 Ruling
MIXED - PARTIAL DENIAL. Section 230 barred all common-law claims, BUT the statutory Texas trafficking claims were allowed to proceed under the FOSTA carve-out.
Status
Statutory claims remanded to proceed in Harris County district court. Final disposition not confirmed in sources reviewed.
Why It Matters
One of very few decisions where a trafficking victim got past 230 - and only via a state statute plus FOSTA. Illustrates how narrow the surviving path is.
Sourcing
State supreme court opinion
Jane Doe v. Apple, Inc. (iCloud CSAM class action) Apple Immunity granted A - Promoted illegal content N.D. Cal. (Judge Noel Wise) 2024
Defendants
Apple Inc.
Court
N.D. Cal. (Judge Noel Wise)
Docket / Citation
No. 24-cv-05107-NW
Filed
Aug. 2024
Who Brought It
9-year-old CSAM victim; putative class of ~2,680 similar victims
Harm Alleged
CSAM sent via iMessage and stored on iCloud after Apple abandoned its announced CSAM-detection system
Theory Pleaded
Products liability, negligence, failure to warn; sought up to $32.8 billion
Section 230 Ruling
IMMUNITY GRANTED - DISMISSED WITH PREJUDICE, July 14, 2026. Judge Wise held Section 230 shields Apple. Notably, the court added that no federal law requires Apple or any tech company to build or deploy CSAM-scanning technology, and that 'lawmakers can fix this problem.'
Status
Closed with prejudice July 14, 2026.
Why It Matters
A federal judge explicitly telling Congress to fix Section 230 while dismissing 2,680 child victims. Among the most citable judicial statements for the site's legislative argument.
Sourcing
Secondary reporting (multiple outlets); underlying order not pulled
Herrick v. Grindr, LLC Grindr Immunity granted A - Promoted illegal content U.S. Court of Appeals, 2d Cir. 2017
Defendants
Grindr
Court
U.S. Court of Appeals, 2d Cir.
Docket / Citation
765 F. App'x 586 (2d Cir. 2019); cert. denied 2019
Filed
2017
Who Brought It
Individual user impersonated on the app
Harm Alleged
Impersonation and stalking - fake profiles directed ~1,100 men to plaintiff's home and workplace
Theory Pleaded
Products liability, negligent design, failure to warn, IIED
Section 230 Ruling
IMMUNITY GRANTED. Nearly all claims barred; the court treated matching and profile display as publishing functions.
Status
Closed.
Why It Matters
Pre-Lemmon high-water mark for platform immunity; often contrasted with Lemmon and Anderson.
Sourcing
Appellate opinion (summary order)
Scott v. Amazon.com, Inc. (sodium nitrite 'suicide kits') Amazon Not reached C - Product recommendation Washington Supreme Court 2022
Defendants
Amazon.com, Inc.
Court
Washington Supreme Court
Docket / Citation
Decided Feb. 23, 2026
Filed
2022-2023 (28 families total)
Who Brought It
Parents/estates of four decedents aged 17-27 who died 2020-2021
Harm Alleged
Sale of 98-99.6% pure sodium nitrite, algorithmically bundled via 'Frequently Bought Together' with antiemetics (Tagamet) and 'The Peaceful Pill Handbook'
Theory Pleaded
Negligence, products liability, failure to warn, no age verification
Section 230 Ruling
NOT THE BASIS OF DECISION. Amazon's appeal turned on superseding cause, not Section 230. Court held suicide did not break the causal chain because 'the decedents' suicide risk was known to Amazon prior to the negligent act.'
Status
CASE PROCEEDS. Washington Supreme Court reversed the intermediate appellate court and allowed the negligence claims to go forward.
Why It Matters
A plaintiff win where the recommendation algorithm itself is the alleged instrument of harm - and where Section 230 gave no shelter because the recommended item was a product, not speech. Sharply illustrates the arbitrariness of the 230 line.
Sourcing
State supreme court decision via legal commentary; opinion text not pulled
Lemmon v. Snap, Inc. Snap Immunity denied B - Design defect U.S. Court of Appeals, 9th Cir. 2019
Defendants
Snap Inc. (Snapchat)
Court
U.S. Court of Appeals, 9th Cir.
Docket / Citation
995 F.3d 1085 (9th Cir. 2021)
Filed
2019
Who Brought It
Parents of three boys killed in a 113 mph crash
Harm Alleged
Snapchat 'Speed Filter' feature allegedly incentivizing high-speed driving
Theory Pleaded
Negligent design - duty framed as independent of any third-party content
Section 230 Ruling
IMMUNITY DENIED. Held the claim rested on Snap's own design of a feature, not on publishing user content, so Section 230 did not apply.
Status
Remanded; resolved below.
Why It Matters
The foundational 'plead around 230' precedent. Every design-defect case since - Neville, the MDL, JCCP 5255 - is built on this template.
Sourcing
Appellate opinion
A.M. v. Omegle.com, LLC Omegle Immunity denied B - Design defect D. Or. 2021
Defendants
Omegle.com LLC
Court
D. Or.
Docket / Citation
614 F. Supp. 3d 814 (D. Or. July 13, 2022)
Filed
2021
Who Brought It
11-year-old girl randomly paired with an adult predator who abused her over three years
Harm Alleged
Child sexual exploitation enabled by random adult-minor pairing
Theory Pleaded
Defective design, negligent design, failure to warn
Section 230 Ruling
IMMUNITY DENIED (in part). Court held Omegle could have satisfied its duty 'by designing a product so that it did not match minors and adults' - no alteration of user content required, so 230 did not bar the design claims.
Status
Settled; Omegle shut down permanently in November 2023, with its founder citing the litigation.
Why It Matters
Rare example of litigation actually removing a harmful service from the internet. Strong evidence that liability changes behavior where immunity does not.
Sourcing
District court opinion
Neville v. Snap, Inc. Snap Immunity denied A/B - Mixed Los Angeles Superior Court (Judge Lawrence Riff) 2022
Defendants
Snap Inc. (Snapchat)
Court
Los Angeles Superior Court (Judge Lawrence Riff)
Docket / Citation
Ruling on demurrer, January 2024
Filed
October 2022
Who Brought It
Families of 60+ children who died of fentanyl poisoning
Harm Alleged
Illegal drug sales - dealers connecting with minors via Quick Add and disappearing messages
Theory Pleaded
Products liability and negligent design - ineffective age verification, lack of parental controls, Quick Add feature 'that facilitates drug dealers' targeting of minors,' ephemeral messaging
Section 230 Ruling
IMMUNITY DENIED. Court accepted that the claims target Snap's own design and business decisions, independent of dealers' content. Widely described as a break from prior 230 doctrine.
Status
Proceeding in L.A. Superior Court. Appellate review by the California Court of Appeal was sought - status not confirmed in sources reviewed; VERIFY before citing as settled law.
Why It Matters
The clearest case of a platform's recommender feature (Quick Add) being alleged to actively connect children to criminals. 60+ dead children makes it the most rhetorically powerful entry on this list.
Sourcing
Secondary reporting and legal commentary; order not pulled
Doe through Roe v. Snap, Inc. Snap Immunity granted B - Design defect U.S. Court of Appeals, 5th Cir. (en banc denied); cert. denied 2022
Defendants
Snap Inc. (Snapchat)
Court
U.S. Court of Appeals, 5th Cir. (en banc denied); cert. denied
Docket / Citation
5th Cir. per curiam (2023); en banc denied 8-7; cert. denied July 2, 2024 (No. 23-961)
Filed
2022
Who Brought It
15-year-old boy groomed by his science teacher
Harm Alleged
Adult-minor sexual grooming via ephemeral/self-deleting messages
Theory Pleaded
Negligent design under Texas law - design encourages minors to lie about age; self-deleting messages enable predation
Section 230 Ruling
IMMUNITY GRANTED. Panel affirmed dismissal per curiam. En banc rehearing failed by one vote, 8-7; the seven dissenters wrote at length against Section 230 doctrine. Justice Thomas, joined by Justice Gorsuch, dissented from the denial of certiorari.
Status
Closed, July 2, 2024.
Why It Matters
A one-vote margin at the en banc stage plus a Supreme Court dissent from two justices. Best available evidence that the judiciary itself is fracturing and wants Congress to act.
Sourcing
Appellate history + Supreme Court docket
Doe v. Grindr Inc. Grindr Immunity granted B - Design defect U.S. Court of Appeals, 9th Cir.; cert. denied 2023
Defendants
Grindr
Court
U.S. Court of Appeals, 9th Cir.; cert. denied
Docket / Citation
No. 24-475 (9th Cir. Feb. 18, 2025); cert. denied Oct. 14, 2025 (No. 24-1202)
Filed
2023
Who Brought It
15-year-old boy matched with and raped by four adult men
Harm Alleged
Child sexual abuse enabled by geolocation matching despite years of warnings
Theory Pleaded
Defective design, negligent design, failure to warn; also a FOSTA/trafficking count
Section 230 Ruling
IMMUNITY GRANTED. Held Section 230 PREEMPTS defective-design claims where the design at issue is the matching function - explicitly narrowing Lemmon.
Status
Closed. Supreme Court denied cert. Oct. 14, 2025.
Why It Matters
Directly conflicts with Anderson v. TikTok and with the 9th Circuit's own Lemmon. Evidence that even the 'design defect' workaround is now closing.
Sourcing
Appellate opinion + Supreme Court docket
Estate of Bride v. YOLO Technologies, Inc. YOLO Partial denial B - Design defect U.S. Court of Appeals, 9th Cir. 2021
Defendants
YOLO Technologies (anonymous messaging app on Snapchat)
Court
U.S. Court of Appeals, 9th Cir.
Docket / Citation
No. 23-55134 (9th Cir. Aug. 22, 2024)
Filed
2021
Who Brought It
Estate of Carson Bride (died by suicide at 16) and three minor plaintiffs
Harm Alleged
Anonymous cyberbullying and harassment
Theory Pleaded
Products liability AND misrepresentation - YOLO publicly promised to unmask and ban abusive users and allegedly never did
Section 230 Ruling
MIXED - PARTIAL DENIAL. Section 230 barred the product-liability claims, BUT the court REVIVED the misrepresentation claims, reasoning that a broken promise is analogous to breach of contract and not a publishing function.
Status
Reversed in part and remanded; misrepresentation claims proceeding.
Why It Matters
Establishes the 'broken safety promise' theory - a route to liability that survives 230 and maps directly onto Big Tech's public safety commitments.
Sourcing
Appellate opinion
In re Social Media Adolescent Addiction/Personal Injury Products Liability Litigation Multiple platforms Partial denial B - Design defect N.D. Cal. (Judge Yvonne Gonzalez Rogers) 2022
Defendants
Meta, Google/YouTube, TikTok/ByteDance, Snap
Court
N.D. Cal. (Judge Yvonne Gonzalez Rogers)
Docket / Citation
MDL No. 3047; 4:22-md-03047-YGR
Filed
Consolidated Oct. 2022
Who Brought It
Individual minors, parents, estates, and school districts (~2,900 member cases as of Aug. 2026)
Harm Alleged
Compulsive-use design, youth mental-health harm, self-harm and eating-disorder content exposure
Theory Pleaded
Products liability, negligent design, failure to warn, public nuisance (school districts)
Section 230 Ruling
LARGELY OVERCOME on design claims. The November 2023 motion-to-dismiss order allowed many design-defect and failure-to-warn theories to proceed while barring claims premised on third-party content.
Status
ACTIVE, growing (~230 new cases in recent weeks). First federal bellwether - Breathitt County (KY) School District v. Meta, Snap, TikTok, YouTube, set for June 15, 2026 - never reached a jury: Snap, TikTok and YouTube settled mid-May 2026, Meta days later on the eve of trial. Combined value reported at roughly $27 million for one rural district.
Why It Matters
The largest private end-user litigation against Big Tech in history. The eve-of-trial settlements suggest defendants will pay almost anything to avoid a jury verdict on the merits.
Sourcing
Secondary reporting; MDL docket not pulled this pass
K.G.M. v. Meta Platforms & YouTube (lead bellwether, JCCP 5255 'Social Media Cases') Multiple platforms Not reached B - Design defect Los Angeles Superior Court 2026
Defendants
Meta, Google/YouTube (Snap and TikTok settled pre-trial)
Court
Los Angeles Superior Court
Docket / Citation
JCCP No. 5255
Filed
Trial began January 2026
Who Brought It
Individual minor plaintiff (bellwether)
Harm Alleged
Compulsive-use design and youth mental-health injury
Theory Pleaded
Products liability, negligent design, failure to warn
Section 230 Ruling
AVOIDED BY PLEADING. Claims framed as first-party design defect; case reached a jury without a dispositive 230 ruling.
Status
VERDICT FOR PLAINTIFF, March 25, 2026: $6M total - $3M compensatory apportioned Meta 70% / Google 30%, plus $3M punitive. Mark Zuckerberg gave his first-ever jury testimony Feb. 18, 2026. Snap and TikTok settled confidentially before/at jury selection. Meta and Google are appealing. Next JCCP bellwethers set for October 2026.
Why It Matters
THE FIRST JURY VERDICT ever against social media platforms for design-based youth harm. Proves juries will assign liability when 230 is taken off the table - the core empirical claim of the repeal argument.
Sourcing
Secondary reporting (multiple outlets); verdict form not pulled
In re Roblox / Discord child exploitation litigation Multiple platforms Contested / undecided A/B - Mixed Federal MDL 2025
Defendants
Roblox Corporation, Discord Inc. (Snap Inc. and TikTok in related suits)
Court
Federal MDL
Docket / Citation
MDL No. 3166
Filed
Consolidated 2025; ~85 cases pending as of Jan. 2026
Who Brought It
Parents of groomed and sexually exploited minors
Harm Alleged
Adult-minor grooming, sextortion, CSAM production; predators moving victims from Roblox to Discord
Theory Pleaded
Negligence, defective design, failure to implement age verification, misrepresentation about safety
Section 230 Ruling
CONTESTED - NOT YET RESOLVED. In August 2026 Roblox, Discord and TikTok moved to dismiss a Kentucky federal suit over a 13-year-old's suicide, arguing Section 230 bars the claims. A July 2026 filing alleges Roblox's facial age-estimation classified a 15-year-old as an adult.
Status
ACTIVE and expanding.
Why It Matters
The newest front, and the one where 'age assurance failed' is pleaded as the platform's own conduct rather than as content moderation - a theory 230 may not reach.
Sourcing
Secondary reporting only - MDL docket not pulled; treat counts as approximate
Garcia v. Character Technologies, Inc. AI developers Not applicable B - Design defect M.D. Fla. (Orlando Div.) 2024
Defendants
Character Technologies, Google LLC, Alphabet Inc., Noam Shazeer, Daniel De Freitas
Court
M.D. Fla. (Orlando Div.)
Docket / Citation
No. 6:24-cv-01903
Filed
October 2024
Who Brought It
Megan Garcia, mother of Sewell Setzer III, who died by suicide at 14
Harm Alleged
AI chatbot fostering an intense emotional/romantic dependency in a minor
Theory Pleaded
Products liability, negligent design, failure to warn, wrongful death
Section 230 Ruling
LARGELY BYPASSED. The May 2025 ruling allowed product-liability claims against an AI chatbot maker to proceed for the first time and rejected a First Amendment dismissal - the AI's output was not treated as protected third-party content.
Status
SETTLED. Parties notified the court on January 7, 2026; case dismissed and closed. Character.AI and Google settled five teen-harm suits together. Terms confidential, no admission of liability.
Why It Matters
Section 230 protects 'information provided by another information content provider.' Generative AI output has no third-party provider - so the immunity arguably evaporates. This is the strongest structural argument that 230 is obsolete.
Sourcing
Secondary reporting + docket listing
Raine v. OpenAI, Inc. AI developers Not applicable B - Design defect San Francisco County Superior Court 2025
Defendants
OpenAI, Inc. and Samuel Altman
Court
San Francisco County Superior Court
Docket / Citation
Filed August 2025
Filed
August 2025
Who Brought It
Matthew and Maria Raine, parents of Adam Raine, who died by suicide at 16 in April 2025
Harm Alleged
ChatGPT allegedly coaching and encouraging suicide
Theory Pleaded
Wrongful death, products liability, negligent design; amended April 2026 to allege INTENTIONAL misconduct - that OpenAI relaxed self-harm safeguards before the death
Section 230 Ruling
NOT APPLICABLE / UNTESTED. As with Garcia, the harmful output is the defendant's own model, so there is no third-party content for 230 to shield.
Status
ACTIVE. OpenAI answered in November 2025 denying responsibility and asserting Adam Raine's 'misuse, unauthorized use, unintended use, unforeseeable use, and/or improper use' of ChatGPT. Jury trial demanded.
Why It Matters
OpenAI's blame-the-dead-teenager defense is the kind of conduct that moves legislators. Also the leading test of whether AI outputs fall outside 230 entirely.
Sourcing
Secondary reporting (multiple outlets); complaint not pulled
Smith v. TikTok Inc. (Arriani Arroyo / Lalani Walton, 'Blackout Challenge') TikTok / ByteDance Unverified A - Promoted illegal content C.D. Cal. 2022
Defendants
TikTok Inc., ByteDance
Court
C.D. Cal.
Docket / Citation
Filed 2022
Filed
June 2022
Who Brought It
Parents of two girls, ages 8 and 9, who died attempting the challenge
Harm Alleged
Asphyxiation challenge videos served by the recommendation algorithm
Theory Pleaded
Products liability, negligent design, wrongful death
Section 230 Ruling
Reported dismissed on Section 230 grounds at the district level, consistent with pre-Anderson doctrine. NOT INDEPENDENTLY VERIFIED.
Status
STATUS NOT CONFIRMED in this research pass. Do not cite without pulling the docket.
Why It Matters
Same fact pattern as Anderson v. TikTok but in the 9th Circuit rather than the 3d - a clean illustration of the circuit split's real-world consequences if confirmed.
Sourcing
UNVERIFIED - flagged for follow-up
Doe v. Backpage.com, LLC (precursor / control case) Backpage Immunity granted A - Promoted illegal content U.S. Court of Appeals, 1st Cir. 2014
Defendants
Backpage.com
Court
U.S. Court of Appeals, 1st Cir.
Docket / Citation
817 F.3d 12 (1st Cir. 2016); cert. denied 2017
Filed
2014
Who Brought It
Three girls trafficked as minors via Backpage escort ads
Harm Alleged
Sex trafficking advertisements
Theory Pleaded
Trafficking Victims Protection Reauthorization Act; state consumer protection
Section 230 Ruling
IMMUNITY GRANTED. Held Section 230 barred claims even against a site whose ad-posting rules were allegedly designed to facilitate trafficking. The court invited Congress to act.
Status
Closed. This decision directly prompted Congress to pass FOSTA-SESTA in 2018.
Why It Matters
The historical proof that Congress CAN amend Section 230 when courts shut victims out - and, read alongside Doe v. Reddit and Doe v. Twitter above, that the 2018 amendment was drawn far too narrowly to work.
Sourcing
Appellate opinion
In re Video Game Addiction Litigation (Xbox and related platforms) Microsoft Not reached B - Design defect Various U.S. district and state courts; JPML centralization DENIED 2025 2024
Defendants
Microsoft (Xbox), plus game developers/publishers
Court
Various U.S. district and state courts; JPML centralization DENIED 2025
Docket / Citation
JPML denied MDL centralization, 2025; individual suits proceeding separately
Filed
2024-2026
Who Brought It
Parents of minors alleging compulsive video-game use
Harm Alleged
Compulsive-use game design (loot boxes, engagement mechanics) - NOT promoted illegal content
Theory Pleaded
Products liability, negligent design, failure to warn
Section 230 Ruling
NOT SQUARELY PRESENTED. Claims target game mechanics rather than third-party content, so Section 230 is largely beside the point - the same pleading posture as MDL 3047.
Status
SCATTERED. The JPML declined to centralize these cases in 2025, so they proceed individually rather than as an MDL. Example: an Illinois mother's suit against Xbox and several developers.
Why It Matters
Included ONLY because the user's request named Microsoft explicitly. This is the sole Microsoft-related end-user harm litigation found, and it is NOT a promoted-illegal-content case. A targeted search for Microsoft/LinkedIn/Xbox content-harm, grooming, and exploitation suits returned nothing - a genuine null result on the question actually asked.
Sourcing
Secondary reporting only - THIN; verify before any use
People of the State of California v. Meta Platforms, Inc. (29-state multistate action) Meta Partial denial D - Government enforcement N.D. Cal. (Judge Yvonne Gonzalez Rogers) 2023
Defendants
Meta (Facebook, Instagram)
Court
N.D. Cal. (Judge Yvonne Gonzalez Rogers)
Docket / Citation
No. 4:23-cv-05448-YGR; related to MDL 4:22-md-03047-YGR
Filed
Oct. 24, 2023
Who Brought It
29 state attorneys general suing parens patriae on behalf of residents
Harm Alleged
Compulsive-use design aimed at minors; under-13 data collection; public misrepresentation about platform dangers
Theory Pleaded
COPPA (15 U.S.C. 6501 et seq.); state Unfair and Deceptive Acts and Practices (UDAP) statutes; unfair competition
Section 230 Ruling
LARGELY OVERCOME. The Oct. 15, 2024 MTD order (Docket #123) let COPPA, consumer-protection and misrepresentation claims proceed. Note: both Meta AND plaintiff-state Colorado noticed appeals from that same order (Docket #143, #146), so it cut both ways.
Status
SETTLED Aug. 26, 2026 - on the ninth day of trial, the same day the jury trial was recorded 'completed.' Up to $17.1-18B over 10 years plus 10-year phased product reforms (time caps, nighttime blackout, muted notifications, age assurance), plus a separate ~$459.3M sub-settlement of Cambridge Analytica-era claims. No admission of liability.
Why It Matters
The first settlement ever to force changes to core product features for ALL users nationwide. Note the gap in press coverage: 29 states litigated, but the Agreement's eligible-jurisdiction roster runs to ~51 once 13 Satellite AG Actions are folded in (see row 39).
Sourcing
PRIMARY - consent judgment and settlement agreement on file at grav/user/legal/; see California_v_Meta_Inc.md and settlement_States_v_MetaInc.md
State of New Mexico ex rel. Torrez v. Meta Platforms, Inc. Meta Immunity denied D - Government enforcement 1st Judicial District Court, Santa Fe County, N.M. (Judge Bryan Biedscheid) 2023
Defendants
Meta (Facebook, Instagram)
Court
1st Judicial District Court, Santa Fe County, N.M. (Judge Bryan Biedscheid)
Docket / Citation
No. D-101-CV-2023-02838
Filed
Dec. 5, 2023
Who Brought It
New Mexico Attorney General Raul Torrez, parens patriae
Harm Alleged
Compulsive-use design; platforms as a vector for child sexual exploitation and sextortion
Theory Pleaded
New Mexico Unfair Practices Act (civil penalties); PUBLIC NUISANCE (abatement)
Section 230 Ruling
IMMUNITY REJECTED - THE SINGLE MOST IMPORTANT 230 RULING ON THIS SHEET. The court expressly rejected Meta's Section 230 defense, an outcome Meta avoided everywhere else nationally.
Status
FINAL JUDGMENT Aug. 6, 2026: $942,000,000 total - $375M in Phase 1 civil penalties (jury found 75,000 UPA violations at the maximum $5,000 each) plus $567M in Phase 2 abatement. Five-year injunctive relief. The court DECLINED to mandate hard age verification, calling that a legislative rather than judicial choice.
Why It Matters
A state won a larger, more punitive outcome by litigating to judgment than the 29 states won by settling - and got the Section 230 ruling the multistate settlement never produced. New Mexico is structurally excluded from the national settlement, which is why.
Sourcing
PRIMARY - judgment PDF on file at grav/user/legal/D-101-CV-2023-02838-Meta-Judgement.pdf
Source
nmdoj.gov ↗
State of New Mexico v. Snap, Inc. Snap Immunity denied D - Government enforcement 1st Judicial District Court, Santa Fe County, N.M. 2024
Defendants
Snap Inc. (Snapchat)
Court
1st Judicial District Court, Santa Fe County, N.M.
Docket / Citation
164-page complaint; unredacted version later filed
Filed
September 2024
Who Brought It
New Mexico Attorney General Raul Torrez, parens patriae
Harm Alleged
CSAM sharing and sextortion; recommendation algorithm alleged to connect adult predators to minors; ephemeral content
Theory Pleaded
New Mexico Unfair Practices Act - addictive design, no meaningful age verification, promotion of harmful content, algorithmic matching
Section 230 Ruling
IMMUNITY REJECTED. The court denied Snap's motion to dismiss in April 2025, rejecting the Section 230 defense and letting the state's case proceed.
Status
ACTIVE. The AG later filed an UNREDACTED complaint exposing internal Snap communications - including a November 2022 internal email indicating Snap was receiving roughly 10,000 sextortion reports per month.
Why It Matters
The internal-documents disclosure is the evidentiary core: it shows actual corporate knowledge of ongoing child exploitation at scale, which is exactly the 'knowledge' element private plaintiffs could never plead well enough to satisfy FOSTA (compare rows 12-13).
Sourcing
State AG press releases; court order not pulled
State of Minnesota v. TikTok Inc. TikTok / ByteDance Immunity denied D - Government enforcement Hennepin County District Court, Minn. (Judge Sullivan) 2025
Defendants
TikTok Inc., ByteDance
Court
Hennepin County District Court, Minn. (Judge Sullivan)
Docket / Citation
MTD argued Dec. 23, 2025; denied Mar. 23, 2026
Filed
Aug. 19, 2025
Who Brought It
Minnesota Attorney General Keith Ellison, parens patriae
Harm Alleged
Compulsive-use design targeting adolescent neurodevelopmental vulnerability; TikTok LIVE paired with unlicensed virtual currency, alleged to have produced documented sexual and financial exploitation of minors
Theory Pleaded
Minnesota consumer protection / deceptive trade practices; illegal money transmission
Section 230 Ruling
IMMUNITY REJECTED - AND SO WAS THE FIRST AMENDMENT DEFENSE. Judge Sullivan: 'Plaintiff is not seeking to impose liability for the specific content available on Defendant's app, but how the app's features are designed to facilitate known harm.' The court also found personal jurisdiction.
Status
ACTIVE. TikTok's motion to dismiss was denied in its entirety on Mar. 23, 2026.
Why It Matters
The cleanest judicial articulation anywhere of the design-versus-content line. That one sentence is the most quotable authority on this sheet for the proposition that regulating recommender design is not regulating speech.
Sourcing
State AG press release + legal trade coverage; order not pulled
Multistate AG enforcement actions against TikTok (14 jurisdictions, filed separately) TikTok / ByteDance Contested / undecided D - Government enforcement 13 state courts plus D.C. Superior Court - separate parallel actions, not consolidated 2024
Defendants
TikTok Inc., ByteDance
Court
13 state courts plus D.C. Superior Court - separate parallel actions, not consolidated
Docket / Citation
Filed as individual state actions
Filed
Oct. 8, 2024
Who Brought It
Coalition co-led by California AG Bonta and New York AG James; joined later by Minnesota, Pennsylvania, Indiana, Utah, Nebraska, Texas, Louisiana and others
Harm Alleged
Addictive recommendation system; also alleged that thousands of underage users hosted TikTok LIVE streams where paid 'gifts' incentivized sexual exploitation of children
Theory Pleaded
State UDAP / consumer protection statutes; false and deceptive representations about platform safety
Section 230 Ruling
MIXED / STILL BEING LITIGATED state by state. Because these are separate suits in separate courts, there is no single ruling - Minnesota's denial of TikTok's MTD (row 35) is the leading favorable outcome so far.
Status
ACTIVE across jurisdictions. Filed deliberately as parallel single-state actions rather than one consolidated case.
Why It Matters
The parallel-filing strategy is itself notable: it forces TikTok to defend the same design theory in a dozen forums at once and maximizes the chance of a favorable precedent somewhere.
Sourcing
Secondary reporting + state AG press releases; individual dockets not pulled
State AG enforcement actions against Roblox and Discord (~11 states) Roblox / Discord Contested / undecided D - Government enforcement Various state courts 2025
Defendants
Roblox Corporation; Discord Inc. (in the Arkansas action)
Court
Various state courts
Docket / Citation
Individual state actions
Filed
Louisiana among the earliest, reported Aug. 14, 2025 (see conflict note); others through 2026
Who Brought It
State attorneys general: Louisiana (Murrill), Texas (Paxton, Nov. 2025), Florida (Dec. 2025), Tennessee, Nebraska (Hilgers), Arkansas (Griffin, June 2026, naming Discord as well), Ohio (Wilson, Aug. 2026, seeking to lead a class action), among others
Harm Alleged
Child sexual exploitation and grooming; failure to require age verification or parental consent; alleged deception of parents about platform safety
Theory Pleaded
State consumer protection / UDAP; deceptive marketing of child safety; negligence
Section 230 Ruling
CONTESTED, NOT YET RESOLVED at the appellate level. The theory is pleaded as deception plus design (age assurance and safety misrepresentation) rather than as content moderation, deliberately following the Minnesota and New Mexico template.
Status
ACTIVE and expanding. Reportedly ~11 states with suits or open investigations; FIVE STATES HAVE ALREADY SETTLED for a combined ~$54 million. Runs parallel to the private MDL 3166 (row 26) and a California coordinated proceeding.
Why It Matters
Shows the AG design/deception theory spreading to a new defendant class within roughly a year - and producing settlements faster than any private litigation track. NOTE: sources conflict on the Louisiana filing date (Aug. 14, 2025 vs. January 2026), so the 'first state to sue Roblox' claim is NOT established.
Sourcing
Secondary reporting; the ~11-state count, the ~$54M settlement total, the Florida AG attribution and the Louisiana filing date are ALL unverified - VERIFY before publication
State AG enforcement actions against Google / YouTube (Nevada; Arkansas) Google / Alphabet Contested / undecided D - Government enforcement Nevada and Arkansas state courts 2025
Defendants
Google LLC, YouTube, Alphabet Inc.
Court
Nevada and Arkansas state courts
Docket / Citation
Separate state actions
Filed
Nevada June 2025 (AG Ford); Arkansas (AG Griffin)
Who Brought It
State attorneys general, parens patriae
Harm Alleged
Addictive platform design aimed at minors; public misrepresentations about safety; alleged contribution to the youth mental-health crisis
Theory Pleaded
State consumer protection / UDAP; deceptive design and marketing
Section 230 Ruling
NOT YET RESOLVED in the sources reviewed. Pleaded on the same design-and-deception theory that has defeated 230 in Minnesota and New Mexico.
Status
ACTIVE. Separately, YouTube was found 30% liable (~$1.8M) in the K.G.M. private bellwether verdict of Mar. 25, 2026 - see row 25.
Why It Matters
Important for scope: YouTube/Google is a defendant in its own right, not merely a co-defendant alongside Meta. Counters the assumption that this litigation wave is only about social media proper. DISAMBIGUATION: Nevada also appears in row 39, but that is Nevada's separate action against META, resolved by the Meta settlement. This row is Nevada v. GOOGLE/YouTube, which is unaffected by it.
Sourcing
State AG press releases; dockets not pulled
Source
ag.nv.gov ↗
'Satellite AG Actions' resolved by the Meta multistate settlement (13 jurisdictions) Meta Not reached D - Government enforcement 13 separate state courts, resolved via the Aug. 26, 2026 federal consent judgment 2026
Defendants
Meta (Facebook, Instagram)
Court
13 separate state courts, resolved via the Aug. 26, 2026 federal consent judgment
Docket / Citation
Defined term within the Settlement Agreement (Docket #572-1)
Filed
Various, pre-Aug. 2026
Who Brought It
Attorneys general of Arkansas, D.C., Iowa, Massachusetts, Mississippi, Montana, Nevada, New Hampshire, Oklahoma, Puerto Rico, Tennessee, Utah and Vermont
Harm Alleged
Same youth design-harm and deception claims as the 29-state action
Theory Pleaded
State UDAP / consumer protection statutes
Section 230 Ruling
NOT REACHED - resolved by settlement before any dispositive Section 230 ruling in these forums.
Status
RESOLVED as part of the Aug. 26, 2026 Meta settlement. The Agreement required 'Minimum State Participation' of at least 40 states or territories to take effect at all.
Why It Matters
These 13 actions are the reconciliation between the '29 states sued' and '52 AGs settled' figures that press coverage reports as if contradictory. Florida and New Mexico are structurally excluded from the eligible roster entirely.
Sourcing
PRIMARY - Settlement Agreement defined terms; see grav/user/legal/settlement_States_v_MetaInc.md

What The Pattern Shows

Filter Who Sued to Private plaintiff and the §230 column reads: nine cases where immunity was granted outright, ten more where the court never reached Section 230 at all because the claim died first on proximate cause,2 and four where immunity was denied.

Filter to Government enforcement and the same column reads differently. Of the four state attorney general actions to reach a dispositive ruling, three denied the Section 230 defence — New Mexico v. Meta, New Mexico v. Snap and Minnesota v. TikTok. Not one attorney general case on this table has lost on Section 230.3

The four private denials do not close the gap, because three of them — Lemmon v. Snap, A.M. v. Omegle and Neville v. Snap — deliberately plead around content, targeting a product feature rather than anything a third party posted. Narrow the table to claims that squarely allege harm from promoted illegal content and exactly one private plaintiff in eighteen has fully defeated the defence:4 Anderson v. TikTok, decided by the Third Circuit in 2024 and now in open conflict with the Second, Fourth and Ninth.5

The mechanism is not that attorneys general have better facts. It is that consumer-protection and public-nuisance statutes let a state plead deception and design — what the company knew, what it told parents, how it built the product — without asking a court to treat the platform as the publisher of any particular post. A parent suing over the specific video that killed their child cannot plead that way, because the specific video is the case.

Two rows state the consequence more plainly than any argument could. In New Mexico ex rel. Torrez v. Meta, the state won a $942 million judgment and an express rejection of the Section 230 defence.6 In Jane Doe v. Apple, a federal judge dismissed a class of roughly 2,680 child sexual-abuse victims with prejudice, observing that no federal law requires any company to deploy detection technology and that "lawmakers can fix this problem."7 Section 230 is not shielding these companies from accountability in general. It is shielding them from their victims in particular.

The clearest judicial statement of the line comes from Minnesota v. TikTok, where the court rejected both the Section 230 and the First Amendment defence:8

Plaintiff is not seeking to impose liability for the specific content available on Defendant's app, but how the app's features are designed to facilitate known harm.

How To Read It

The Claim Type filter is the distinction that everything else depends on, and press coverage collapses it constantly.

A — Promoted illegal content is the genuine Section 230 battleground: the plaintiff says a third party created something unlawful and the platform's recommender pushed it at them. B — Design defect claims are pleaded to avoid that fight, targeting a feature rather than any content; this is where nearly all the filings and nearly all the plaintiff victories are, precisely because they never test the immunity. A/B — Mixed marks two entries whose facts are squarely category A — fatal drug sales, child sexual exploitation — but which had to be pleaded as design defect to survive. C — Product recommendation is a single case, Scott v. Amazon, where the algorithm promoted a lethal product rather than speech, and Section 230 never applied. D — Government enforcement is the attorney general track.

Never cite a category B outcome as evidence that victims can recover for promoted-content harm. They win by not alleging it.

Two further cautions govern any use of this table. Multi-district litigation is counted once. MDL 3047 alone holds roughly 2,900 member cases and MDL 3166 around 85;9 enumerating members would drown the distinct cases in duplicates. Each consolidated proceeding is a single row, with separate rows only for named bellwethers that produced a verdict or a significant ruling. Status rots. Appellate courts reverse: the Buffalo massacre suit survived dismissal in March 2024 and was thrown out on Section 230 grounds in July 2025.10 Every row is pinned to the date at the top of this page.

What It Covers, And What It Does Not

This table is not a census of technology litigation and does not claim to be one.

Coverage is close to exhaustive for private suits alleging harm from promoted illegal content — the terrorism cases under the Anti-Terrorism Act, the child sexual abuse material and trafficking cases, and the recommendation-driven death cases — together with the leading design-defect precedents that shaped how those claims must now be pleaded. Two historical controls are included deliberately: Doe v. Backpage, the 2016 decision that provoked FOSTA-SESTA, and Herrick v. Grindr, the high-water mark of platform immunity before Lemmon.

Excluded by design: antitrust, privacy and biometric claims, and shareholder suits. Those are different theories about different harms and belong to antitrust. Bills, statutes and executive orders are not here either — they are the subject of the companion legislation tracker, which excludes litigation for the same reason this page excludes legislation. For what Section 230 says and how the courts expanded it, see Section 230. The two Meta actions summarised in rows 32 and 33 have their own detailed treatments: the settlement and the state attorneys general timeline.

Microsoft appears once, and the entry is a negative result. A targeted search for suits against Microsoft, LinkedIn or Xbox alleging harm from promoted illegal content returned nothing. The single Microsoft row is video-game addiction litigation, which is a design-defect claim, and it is marked as such rather than left as an unexplained absence.11

Three external trackers cover ground this page deliberately does not, and are the right starting points for anyone extending it.12

Rows That Are Not Yet Adequately Sourced

Every row carries a Sourcing field in its detail view, distinguishing entries read from an actual judicial opinion from those resting on press reports or attorney general announcements. Six items are not yet verified to the standard the rest of this site holds, and are flagged here rather than quietly left to be discovered:

  • Patterson v. Meta (Buffalo). The July 2025 Fourth Department reversal is reported by several outlets but the opinion has not been read, and whether the New York Court of Appeals has taken the case is unknown.
  • Neville v. Snap. The January 2024 ruling is well documented in commentary, but the appellate posture in the California Court of Appeal is unconfirmed.
  • Smith v. TikTok. Status unverified entirely. It should not be cited before the docket is pulled.
  • The Roblox and Discord attorney general actions. The state count, the reported combined settlement figure and the Louisiana filing date are all secondary-sourced, and two sources give irreconcilable Louisiana dates, so no claim is made about which state sued first. One source attributes the Florida filing to an attorney general who had already left office, so no Florida attorney general is named.
  • The Minnesota, multistate TikTok and Google/YouTube rows. Sourced to attorney general press releases, which are not disinterested about their own victories. The Minnesota v. TikTok quotation above should be checked against the order itself before it is relied on.
  • The Xbox row, as described above.

The underlying spreadsheet, with the same columns and the same flags, is kept alongside the primary case documents in the site's research directory. Where the two differ, the CSV published beside this page is the authoritative version.13


  1. The §230 Result column is a classification made for this page, not a label any court applied to itself. Each row's full ruling text is preserved verbatim in the expanded detail view, and the short value is derived from that text mechanically — by ordered prefix rules in the conversion script, never typed per row — so the summary cannot drift from the prose it summarises. Seven values are possible: immunity granted, immunity denied, partial denial, not reached, not applicable, contested / undecided, and unverified. Open a row and compare the ruling text against the label if you doubt any single classification; that is what the detail view is for. 

  2. These are almost entirely the Anti-Terrorism Act cases — Fields, Crosby, Colon, Retana, Clayborn, and ultimately Gonzalez and Taamneh themselves. They matter to the argument precisely because they are not Section 230 wins for the platforms: the courts never got that far, dismissing on the ATA's proximate-causation and aiding-and-abetting elements first. This is the stronger form of the point. A victim of promoted terrorist content frequently cannot obtain a Section 230 ruling at all, favourable or otherwise, because a different doctrine disposes of the case earlier. Anyone citing "platforms keep winning on 230" should know that in seven of these cases the immunity was never actually tested. 

  3. Read this as a statement about a small decided sample, not a law of nature. Eight attorney general rows appear on the table, but only four have produced a dispositive ruling on the defence; the rest settled before one, or are still being briefed. Three of those four denied immunity and the fourth (California v. Meta) allowed the COPPA and consumer-protection claims through in part. A single adverse appellate ruling would change the sentence, and three of the eight AG rows rest on press releases rather than orders — see the flagged list above. The claim is that no attorney general action on this table has yet lost on Section 230, which is a narrower and more defensible thing than "attorneys general cannot lose." 

  4. The denominator is the eighteen private rows in category A. They break down as seven immunity granted, seven never reaching Section 230, two partial denials (Doe #1 v. Twitter and In re Facebook, each surviving only on a narrow statutory sliver), one immunity denied (Anderson), and one unverified (Smith v. TikTok, counted in the denominator but not claimed as a loss, since its status has not been confirmed). Filter the table to Private plaintiff plus A — Promoted illegal content to reproduce the count. 

  5. Anderson v. TikTok, 116 F.4th 180 (3d Cir. 2024) — the precedential opinion holds that algorithmic curation of a For You Page is the platform's own first-party expressive activity, and so is not "information provided by another" within §230(c)(1). The most important open question on this page is what happens to it next. The decision only reversed a dismissal; it was remanded to the Eastern District of Pennsylvania and has never been tested on the merits, so no plaintiff has yet recovered on the theory. The remand docket is the single most valuable thing to watch, and a Supreme Court grant on the resulting circuit split — against the Second (Force), Fourth (M.P.) and Ninth (Doe v. Grindr) — would be the most consequential development possible for everything on this table. 

  6. The judgment itself is held with the site's research materials rather than being quoted from press coverage, and the New Mexico Department of Justice announcement summarises it. One qualification belongs with any use of this figure: the court declined to order hard age verification, holding that "sweeping policy choices of that kind belong to the legislative and executive branches, not the courts." New Mexico is therefore not a total victory even on its own terms — the presiding judge said in substance that the remedy is incomplete without legislation, which is the argument this site makes. 

  7. Quoted from contemporaneous reporting of the 14 July 2026 dismissal (9to5Mac and others), not from the order, which has not been pulled. Given how much rhetorical weight a federal judge telling Congress to fix the statute can carry, the order in Doe v. Apple, No. 24-cv-05107-NW (N.D. Cal.), should be obtained from PACER or CourtListener and the wording checked before the sentence is quoted in advocacy or testimony. 

  8. The quotation comes from the Minnesota Attorney General's own announcement of the 23 March 2026 ruling, which is a party's characterisation of its own win and not a neutral report. The underlying order of the Hennepin County District Court has not been read. Treat the wording as provisional: it is quoted here because it states the design-versus-content distinction more crisply than any other source found, which is exactly why it should be verified before it is relied on. 

  9. Both counts are approximate and drawn from commercial multi-district-litigation trackers rather than the courts. They also move constantly — MDL 3047 was reported as growing by roughly 230 cases in a matter of weeks. The authoritative figure is the Judicial Panel on Multidistrict Litigation's own monthly pending-case statistics, which is where these numbers should be refreshed at each review. 

  10. Patterson v. Meta Platforms, Inc. is the sharpest illustration of why every row here carries a date. Justice Feroleto allowed claims against YouTube and Reddit to proceed in March 2024; the Appellate Division, Fourth Department reversed on Section 230 grounds in July

    1. Whether the New York Court of Appeals has granted leave to appeal is unknown to this page, and the Fourth Department's opinion has not been read — both are listed among the unsourced rows above. Anyone extending this table should resolve that first: it is the broadest defendant list of any private suit here, naming Meta, Google, Amazon, Reddit and Discord together.

  11. The search covered Microsoft, LinkedIn and Xbox against content-harm, grooming and exploitation claims. A targeted search is not an exhaustive one, and a negative result of this kind is weaker evidence than a positive one — it establishes that no such suit was prominent enough to surface, not that none exists. It is recorded as a row rather than an omission so that a reader who wonders why the largest software company is missing gets an answer instead of a silence. 

  12. For the terrorism cases specifically, the George Washington University Program on Extremism maintains a fuller enumeration of terrorism lawsuits against social media companies than the seven representative Anti-Terrorism Act entries kept here. For new filings and ongoing status, the Tech Justice Law Project's litigation tracker, hosted at Tech Policy Press, is the best continuously-updated source and is where this page should be refreshed from. For doctrinal analysis of individual Section 230 rulings, Eric Goldman's Technology & Marketing Law Blog covers nearly every decision on this table, usually within days, and is cited as the source for several rows — with the caveat that it is openly critical of attempts to narrow the immunity, and should be read as informed advocacy rather than neutral reporting. Federal dockets themselves are free on CourtListener

  13. litigation.csv, published in this page's own directory, is the human-editable source of truth; litigation.json, which the table actually renders, is generated from it by themes/quark2/tools/csv-to-json.py and should never be hand-edited. Both are committed, so the table can be audited or rebuilt from the repository alone. A working copy of the same research also sits with the primary case documents in the site's research directory, outside version control — it will drift, and the published CSV wins.