The Case That Will Change the Internet Forever: Gonzalez v. Google LLC

Facts of the case
This case arises from the same set of facts as Twitter v. Taamneh.

Nohemi Gonzalez, a U.S. citizen, was killed by a terrorist attack in Paris, France, in 2015—one of several terrorist attacks that same day. The day afterwards, the foreign terrorist organization ISIS claimed responsibility by issuing a written statement and releasing a YouTube video. Gonzalez’s father filed an action against Google, Twitter, and Facebook, claiming, among other things, that Google aided and abetted international terrorism by allowing ISIS to use its platform—specifically YouTube—“to recruit members, plan terrorist attacks, issue terrorist threats, instill fear, and intimidate civilian populations.” Specifically, the complaint alleged that because Google uses computer algorithms that suggest content to users based on their viewing history, it assists ISIS in spreading its message.

Gonzalez claimed that all three platforms were also liable for aiding and abetting international terrorism by failing to take meaningful or aggressive action to prevent terrorists from using its services, even though they did not play an active role in the specific act of international terrorism that actually injured Gonzalez.

The district court granted Google’s motion to dismiss the claim based on Section 230, and the U.S. Court of Appeals for the Ninth Circuit affirmed.

Question
Does Section 230(c)(1) of the Communications Decency Act immunize interactive computer services when they make targeted recommendations of information provided by another information content provider?