Amazon.com scored a Ninth Circuit win on Section 230 grounds when the court affirmed the lower court’s summary judgment against a pro se plaintiff’s claim against Amazon for tortious interference with prospective and actual business relations, and interference with an economic advantage. The claim apparently arose out of a third party posting a review on Amazon that plaintiff did not like. Citing to Barnes v. Yahoo!, Inc., 570 F.3d 1096 (9th Cir. 2009), the court observed that the Communications Decency Act (at Section 230(c)(1)) provides immunity from liability if a claim “inherently requires the court to treat the defendant as the ‘publisher or speaker’ of content provided by another.” Plaintiff had failed to raise a genuine dispute of material fact as to whether Amazon was not a publisher or speaker of content within the meaning of Section 230.

Sen v. Amazon.com, 2020 WL 708701 (9th Cir. February 12, 2020)