Section 230 Helps Discord Defeat “Defective Design” Claims Regarding Sexual Predation–Jane Doe v. Discord

This is another entry in the genre of “predator access” cases claiming that predators solicited minors for sex online, in this case on Discord. Many predator access cases have targeted Roblox, which has a pending MDL in CA consolidating dozens of cases. Some of those plaintiffs have also named Discord. The plaintiffs tried to get this case moved to the Northern District of California so that it could operate in parallel with the Roblox MDL, but the court refuses that request. Instead, the court hands Discord a decisive win per Section 230. The court starts off with this broad proposition: Section 230 compels dismissal of claims seeking to hold platforms liable for activity amounting to sexual exploitation of one user by another when the factual predicate is that the two users engaged in messaging using the platform’s service” [cites to Doe v. Grindr, Doe v. MySpace, Doe v. Snap, Doe 1 v. Backpage, Doe II v. MySpace, In re Facebook, LW v. Snap, Doe v. Grindr (S.D. Fla.), Doe v. Kik.]…