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This Supreme Court Case Could Decide The Future Of The Internet As We Know It



This Supreme Court Case Could Decide The Future Of The Internet As We Know It

The Supreme Court will soon hear arguments in a case with major implications for the operation of the internet as we know it. In Gonzalez v. Google, set to be argued Feb. 21, the court will be asked to pass judgment on Section 230 of the Communications Decency Act for the first time.

Since its enactment in 1996, Section 230 has been interpreted by courts to shield online platforms from liability for almost any offense committed by users. This protection for user behavior enabled the growth of the current online ecosystem of search engines, social media sites, blogs, message boards, user-generated encyclopedias and shopping sites. And so it has variously been dubbed the internet’s “Magna Carta,” its “First Amendment” and the “Twenty-Six Words That Created The Internet.”

But Section 230 has also produced negative effects. Online platforms have been used for harassment, death threats, defamation, discrimination, revenge porn, fraudulent product sales, the illegal purchase of weapons and drugs resulting in death, and other illicit behavior. In most cases, platforms have been absolved of any responsibility thanks to Section 230’s protections. Gonzalez v. Google brings the negative effects that come with Section 230 before the court for the first time.

In 2015, Islamic State-linked militants murdered 23-year old American student Nohemi Gonzalez amid a terrorist attack in Paris that left 129 people dead. Gonzalez’s family sued Google for aiding and abetting terrorism under the Anti-Terrorism Act. The family claimed that YouTube’s algorithmic recommendation engine suggested and promoted videos posted by the Islamic State that recruited followers and encouraged violence. At issue in the case is whether or not these algorithms are themselves covered by Section 230’s liability protection.

The U.S. Court of Appeals for the 9th Circuit ruled in 2021 that Google’s YouTube recommendation algorithm is protected by Section 230, but the decision featured notable dissenting opinions.

These dissents joined an increasing range of criticism of Section 230 from women’s rights advocates, antitrust reformers and conservatives. With the issue finally before the Supreme Court, these challengers ask the justices to consider whether the internet has changed so much in the past 30 years that it’s time to reconsider the law that made it what it is today.

From The Wolf Of Wall Street To Oklahoma City

Section 230 emerged from very specific circumstances that arose during the early public adoption of the internet in the 1990s. It started with two court cases that created perverse incentives that could doom the nascent technology.

In 1991, the online service CompuServe was sued for defamation over user posts made on a message board it hosted. A court in New York found CompuServe not liable as a publisher because it did not edit, moderate or review any content posted on the bulletin boards it operated.

Four years later, Stratton Oakmont, the brokerage firm whose founder Jordan Belfort was immortalized in Martin Scorsese’s movie “The Wolf of Wall Street,” sued the internet service provider Prodigy over alleged defamatory posts made on one of its message boards. Unlike CompuServe, Prodigy engaged in content moderation in order to remove profanity and pornography. A New York state court found Prodigy liable for defamation posted by its users because it proactively removed objectionable content.

These two cases set off alarm bells for the burgeoning online industry. It looked like companies would be punished for good behavior and protected for giving free rein to bad behavior.

The 1990s message board provider CompuServe was involved in one of the early online defamation cases that gave rise to Section 230.

Patrick Durand via Getty Images

Then-Rep. Chris Cox, a California Republican, thought the same thing when reading about the cases in the paper. And so he teamed up with Rep. Ron Wyden, who is now a Democratic senator from Oregon, to do something about it. The law they wrote became Section 230 of the Communications Decency Act of 1996.

The law, named the Good Samaritan Act, gave internet content service providers liability protection when they acted to remove objectionable content. This meant that online sites would not be penalized in court as publishers of user content as Prodigy was for engaging in content moderation. It features two key passages.

“No provider or user of an interactive computer service shall be treated as the publisher or speaker of any information provided by another information content provider,” the first passage states. These are the aforementioned 26 words that “created the internet.”

The other key passage states that online content providers are immune from liability for “any action voluntarily taken in good faith to restrict access to or availability of material that the provider or user considers to be obscene, lewd, lascivious, filthy, excessively violent, harassing, or otherwise objectionable, whether or not such material is constitutionally protected” or “any action taken to enable or make available to information content providers or others the technical means to restrict access to” such material. This provides the Good Samaritan protection for content moderation.

The new law was quickly tested in the courts. The first such case emerged in the wake of the Oklahoma City bombing when an anonymous AOL user posted an offer to sell pro-Timothy McVeigh bumper stickers, and attached the name and address of one Ken Zeran. Zeran, who was not behind the bumper stickers, received a torrent of death threats and abuse. He asked AOL to take down the messages, and the company did, but they kept reappearing. Zeran ultimately sued AOL for negligence for failing to keep the messages off of the platform.

In 1998, the 4th Circuit U.S. Court of Appeals ruled that Section 230 protected AOL from claims of negligence, or any other possible criminal liability, whether as a publisher or as a distributor, because the law “creates a federal immunity to any cause of action that would make service providers liable for information originating with a third-party user of the service.”

Ever since the Zeran decision, federal and state courts have applied this near-blanket “federal immunity” to protect digital platforms from liability for user-generated content. This new exemption from secondary liability encouraged the nascent tech industry to move away from content generation and toward the creation of user-generated platforms. The companies that emerged from this change in liability law like Amazon, Google and Facebook are today among the highest-capitalized companies in the world.

Are Recommendations The Same As Publishing?

As the tech industry emerged from its position as an upstart into the home of the most valuable companies in the world, the perverse consequences of Zeran’s broad grant of Section 230 immunity came more and more into focus.

For social media platforms in particular, this included the understanding that their owners prioritized the maximization of the time users spent on their site in order to increase ad revenue. Platforms built recommendation algorithms that prioritized keeping eyeballs engaged. They also built targeted advertising systems and algorithms for one class of user — advertisers — to connect with another.

In the race to monopolize user attention, social media companies built their platforms and the algorithms that unearthed engaging content in order to hook their users. One of the most read books by Silicon Valley executives as this attention economy emerged was called “Hooked: How to Build Habit-Forming Products.” In this push for money and power, these companies wound up hosting and promoting to their users content from all kinds of sources, including terrorists, racist extremists, misogynists and many others who ultimately became linked to bombings, murders and mass shootings.

“In my view, these types of targeted recommendations and affirmative promotion of connections and interactions among otherwise independent users are well outside the scope of traditional publication.”

– Judge Marsha Berzon, 9th U.S. Circuit Court of Appeals

Section 230 had long been cited in lower courts as providing liability protection in almost every case of platform-hosted user-generated content. Would it apply when that user-generated content was recommended by an algorithm or other system created by the platform itself? A few key lower court cases precede Google v. Gonzalez in addressing this question.

In a nearly identical case, Force v. Facebook, U.S. victims of terrorist attacks in Israel and their families sued the social media company alleging it aided and abetted terrorism under the Anti-Terrorism Act by hosting and promoting content from the group Hamas through its recommendation algorithms.

On appeal, the 2nd Circuit U.S. Court of Appeals ruled in favor of Facebook by holding that the use of neutral algorithms to suggest or recommend content was the action of a publisher, which Section 230 protects from liability.

“Arranging and distributing third-party information inherently forms ‘connections’ and ‘matches’ among speakers, content, and viewers of content, whether in interactive internet forums or in more traditional media. That is an essential result of publishing,” the court’s majority opinion stated.

Many online platforms do not use as sophisticated recommendation systems as Facebook or YouTube do, and they too won protection from liability under Section 230.

In Dyroff v. Ultimate Software Group, the mother of Wesley Greer sued Ultimate Software Group after Greer purchased fentanyl-tainted heroin from a drug dealer through the company’s website The Experience Project. That site allowed users to post questions or comments and then suggested connections that would appeal to them. It also alerted them when other users responded. In Greer’s case, he asked where he could find heroin near him. The site then emailed him when another user responded with an offer to sell him drugs.

The 9th Circuit ultimately ruled that the site’s “recommendation and notification functions … did not materially contribute … to the alleged unlawfulness of the content” and were “neutral,” making them just another function of publishing.

‘Proactively Creating Networks’

While these rulings uphold the long-standing lower court consensus on Section 230, a number of notable dissents have emerged along with them.

In the Force v. Facebook case, 2nd Circuit Chief Judge Robert Katzmann, a Bill Clinton appointee who died in 2021, issued a partial concurrence and dissent arguing that Section 230 should not be read to cover the recommendation algorithms created by social media sites.

“Through its use of friend, group, and event suggestions, Facebook is doing more than just publishing content: it is proactively creating networks of people,” Katzmann wrote. “Its algorithms forge real-world (if digital) connections through friend and group suggestions, and they attempt to create similar connections in the physical world through event suggestions.”

By “proactively creating networks of people” through friend, group and interest suggestions, Facebook, Katzmann argued, produces a “cumulative effect” that is “greater than the sum of each suggestion.” These suggestions have the potential to immerse a user “in an entire universe filled with people, ideas, and events she may never have discovered on her own.”

People gather at a makeshift memorial near the Bataclan concert hall in Paris on Nov. 15, 2015, two days after a series of deadly attacks by Islamic State militants where American citizens including Nohemi Gonzalez were killed. Gonzalez's family is suing Google for aiding ISIS by distributing its videos over YouTube.
People gather at a makeshift memorial near the Bataclan concert hall in Paris on Nov. 15, 2015, two days after a series of deadly attacks by Islamic State militants where American citizens including Nohemi Gonzalez were killed. Gonzalez’s family is suing Google for aiding ISIS by distributing its videos over YouTube.

MIGUEL MEDINA via Getty Images

“It strains the English language to say that in targeting and recommending these writings to users — and thereby forging connections, developing new social networks — Facebook is acting as ‘the publisher of … information provided by another information content provider,’” he continued.

Judges on the 9th Circuit echoed Katzmann’s arguments in a concurrence and a partial dissent when they heard Gonzalez.

In joining “the growing chorus of voices calling for a more limited reading of the scope of Section 230 immunity,” Judge Marsha Berzon, a Clinton appointee, wrote in a concurrence that she would find that “the term ‘publisher’ under section 230” does not cover “activities that promote or recommend content or connect content users to each other.”

“In my view, these types of targeted recommendations and affirmative promotion of connections and interactions among otherwise independent users are well outside the scope of traditional publication,” she added.

In a separate concurrence and partial dissent, Judge Ronald Gould, a Clinton appointee, agreed that Section 230 protects Google from liability for posts published by ISIS members on YouTube, but not for any activity that “goes beyond merely publishing the post” like “amplifying” dangerous content such as terrorism recruitment videos.

The plaintiffs in Gonzalez point to these dissents to argue that Section 230 protection should not extended to cover these recommendation systems. This wouldn’t necessarily lead to Google being found in violation of the Anti-Terrorism Act, but it would enable a court challenge to proceed.

Friend-of-the-court briefs similarly argue that the Supreme Court could limit Section 230 immunity in a variety of ways. The court could find that certain acts of curation and recommendation are not acts of publishing. It could rule that Section 230 protects online companies as “publishers,” but not as “distributors” of third-party content. Or it could require companies to act as good Samaritans, as suggested by the law’s original title, and eliminate harmful conduct or protect users from it on their platforms when they are made aware of it.

At The Supreme Court

Since the Supreme Court has not heard a Section 230 case before, the justices have had little to say about it. The only exception is Justice Clarence Thomas, who in 2020 noted his dissatisfaction with lower courts’ interpretation of Section 230.

Noting that “most of today’s major Internet platforms did not exist” when Section 230 was enacted, Thomas said it “behooves” the court to take up a case challenging the law to judge whether lower courts have extended the protection from liability suits too far.

“Adopting the too-common practice of reading extra immunity into statutes where it does not belong, courts have relied on policy and purpose arguments to grant sweeping protection to Internet platforms,” Thomas wrote in dissent from a decision to turn down a case.

No other justice has stated an opinion on Section 230. There is also no way to divine their potential opinions based on which party’s president appointed them or their identification as conservative or liberal. Thomas, a George H.W. Bush appointee, is the most conservative justice on the court, while the three dissenting lower court judges were all liberals appointed by Clinton. Thomas’ call for the court to hear a Section 230 case also came amid rising skepticism toward Section 230 from members of both political parties.

Democrats in Congress introduced legislation to limit Section 230 liability protections for online advertisements and certain health information, and for online platforms that enable discrimination, stalking, harassment, genocide or wrongful death. Meanwhile, Republicans seek to amend Section 230 by having its liability protections kick in only when companies do not censor or otherwise moderate political opinions.

Gonzalez may very well be the beginning of a new legal landscape for the internet. The Supreme Court is currently weighing whether to take up arguments in two cases challenging laws passed by Republicans in Florida and Texas that would ban digital platforms from moderating content based on political ideology. In a hint that they might take the cases, the court asked the Biden administration to submit a brief in the Florida case on Jan. 23.

Changes to the internet’s “Magna Carta,” however well-meaning, may result in unwanted consequences. After a court found that Section 230 provided liability protection to the sex-worker website for connecting users with underage sex workers, Congress passed a law denying Section 230 protection to platforms engaged in sex-trafficking. This resulted in the shuttering of sites where sex workers consensually offered their services and Craigslist removing its entire personal ads section.

Just as Section 230 was enacted in response to the “perverse incentives” created by the Stratton Oakmont decision, and its passage created its own incentives protecting the internet’s negative externalities, so too could any change dictated by the court.

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12 Proven Methods to Make Money Blogging in 2024



Make money blogging


Make money bloggingThis is a contributed article.

The world of blogging continues to thrive in 2024, offering a compelling avenue for creative minds to share their knowledge, build an audience, and even turn their passion into profit. Whether you’re a seasoned blogger or just starting, there are numerous effective strategies to monetize your blog and achieve financial success. Here, we delve into 12 proven methods to make money blogging in 2024:

1. Embrace Niche Expertise:

Standing out in the vast blogosphere requires focus. Carving a niche allows you to cater to a specific audience with targeted content. This not only builds a loyal following but also positions you as an authority in your chosen field. Whether it’s gardening techniques, travel hacking tips, or the intricacies of cryptocurrency, delve deep into a subject you’re passionate and knowledgeable about. Targeted audiences are more receptive to monetization efforts, making them ideal for success.

2. Content is King (and Queen):

High-quality content remains the cornerstone of any successful blog. In 2024, readers crave informative, engaging, and well-written content that solves their problems, answers their questions, or entertains them. Invest time in crafting valuable blog posts, articles, or videos that resonate with your target audience.

  • Focus on evergreen content: Create content that remains relevant for a long time, attracting consistent traffic and boosting your earning potential.
  • Incorporate multimedia: Spice up your content with captivating images, infographics, or even videos to enhance reader engagement and improve SEO.
  • Maintain consistency: Develop a regular publishing schedule to build anticipation and keep your audience coming back for more.

3. The Power of SEO:

Search Engine Optimization (SEO) ensures your blog ranks high in search engine results for relevant keywords. This increases organic traffic, the lifeblood of any monetization strategy.

  • Keyword research: Use keyword research tools to identify terms your target audience searches for. Strategically incorporate these keywords into your content naturally.
  • Technical SEO: Optimize your blog’s loading speed, mobile responsiveness, and overall technical aspects to improve search engine ranking.
  • Backlink building: Encourage other websites to link back to your content, boosting your blog’s authority in the eyes of search engines.

4. Monetization Magic: Affiliate Marketing

Affiliate marketing allows you to earn commissions by promoting other companies’ products or services. When a reader clicks on your affiliate link and makes a purchase, you get a commission.

  • Choose relevant affiliates: Promote products or services that align with your niche and resonate with your audience.
  • Transparency is key: Disclose your affiliate relationships clearly to your readers and build trust.
  • Integrate strategically: Don’t just bombard readers with links. Weave affiliate promotions naturally into your content, highlighting the value proposition.

5. Display Advertising: A Classic Approach

Display advertising involves placing banner ads, text ads, or other visual elements on your blog. When a reader clicks on an ad, you earn revenue.

  • Choose reputable ad networks: Partner with established ad networks that offer competitive rates and relevant ads for your audience.
  • Strategic ad placement: Place ads thoughtfully, avoiding an overwhelming experience for readers.
  • Track your performance: Monitor ad clicks and conversions to measure the effectiveness of your ad placements and optimize for better results.

6. Offer Premium Content:

Providing exclusive, in-depth content behind a paywall can generate additional income. This could be premium blog posts, ebooks, online courses, or webinars.

  • Deliver exceptional value: Ensure your premium content offers significant value that justifies the price tag.
  • Multiple pricing options: Consider offering tiered subscription plans to cater to different audience needs and budgets.
  • Promote effectively: Highlight the benefits of your premium content and encourage readers to subscribe.

7. Coaching and Consulting:

Leverage your expertise by offering coaching or consulting services related to your niche. Readers who find your content valuable may be interested in personalized guidance.

  • Position yourself as an expert: Showcase your qualifications, experience, and client testimonials to build trust and establish your credibility.
  • Offer free consultations: Provide a limited free consultation to potential clients, allowing them to experience your expertise firsthand.
  • Develop clear packages: Outline different coaching or consulting packages with varying time commitments and pricing structures.

8. The Power of Community: Online Events and Webinars

Host online events or webinars related to your niche. These events offer valuable content while also providing an opportunity to promote other monetization avenues.

  • Interactive and engaging: Structure your online events to be interactive with polls, Q&A sessions, or live chats. Click here to learn more about image marketing with Q&A sessions and live chats.

9. Embrace the Power of Email Marketing:

Building an email list allows you to foster stronger relationships with your audience and promote your content and offerings directly.

  • Offer valuable incentives: Encourage readers to subscribe by offering exclusive content, discounts, or early access to new products.
  • Segmentation is key: Segment your email list based on reader interests to send targeted campaigns that resonate more effectively.
  • Regular communication: Maintain consistent communication with your subscribers through engaging newsletters or updates.

10. Sell Your Own Products:

Take your expertise to the next level by creating and selling your own products. This could be physical merchandise, digital downloads, or even printables related to your niche.

  • Identify audience needs: Develop products that address the specific needs and desires of your target audience.
  • High-quality offerings: Invest in creating high-quality products that offer exceptional value and user experience.
  • Utilize multiple platforms: Sell your products through your blog, online marketplaces, or even social media platforms.

11. Sponsorships and Brand Collaborations:

Partner with brands or businesses relevant to your niche for sponsored content or collaborations. This can be a lucrative way to leverage your audience and generate income.

  • Maintain editorial control: While working with sponsors, ensure you retain editorial control to maintain your blog’s authenticity and audience trust.
  • Disclosures are essential: Clearly disclose sponsored content to readers, upholding transparency and ethical practices.
  • Align with your niche: Partner with brands that complement your content and resonate with your audience.

12. Freelancing and Paid Writing Opportunities:

Your blog can serve as a springboard for freelance writing opportunities. Showcase your writing skills and expertise through your blog content, attracting potential clients.

  • Target relevant publications: Identify online publications, websites, or magazines related to your niche and pitch your writing services.
  • High-quality samples: Include high-quality blog posts from your site as writing samples when pitching to potential clients.
  • Develop strong writing skills: Continuously hone your writing skills and stay updated on current trends in your niche to deliver exceptional work.


Building a successful blog that generates income requires dedication, strategic planning, and high-quality content. In today’s digital age, there are numerous opportunities to make money online through blogging. By utilizing a combination of methods such as affiliate marketing, sponsored content, and selling digital products or services, you can leverage your blog’s potential and achieve financial success.

Remember, consistency in posting, engaging with your audience, and staying adaptable to trends are key to thriving in the ever-evolving blogosphere. Embrace new strategies, refine your approaches, and always keep your readers at the forefront of your content creation journey. With dedication and the right approach, your blog has the potential to become a valuable source of income and a platform for sharing your knowledge and passion with the world, making money online while doing what you love.

Image Credit: DepositPhotos

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Snapchat Explores New Messaging Retention Feature: A Game-Changer or Risky Move?




Snapchat Explores New Messaging Retention Feature: A Game-Changer or Risky Move?

In a recent announcement, Snapchat revealed a groundbreaking update that challenges its traditional design ethos. The platform is experimenting with an option that allows users to defy the 24-hour auto-delete rule, a feature synonymous with Snapchat’s ephemeral messaging model.

The proposed change aims to introduce a “Never delete” option in messaging retention settings, aligning Snapchat more closely with conventional messaging apps. While this move may blur Snapchat’s distinctive selling point, Snap appears convinced of its necessity.

According to Snap, the decision stems from user feedback and a commitment to innovation based on user needs. The company aims to provide greater flexibility and control over conversations, catering to the preferences of its community.

Currently undergoing trials in select markets, the new feature empowers users to adjust retention settings on a conversation-by-conversation basis. Flexibility remains paramount, with participants able to modify settings within chats and receive in-chat notifications to ensure transparency.

Snapchat underscores that the default auto-delete feature will persist, reinforcing its design philosophy centered on ephemerality. However, with the app gaining traction as a primary messaging platform, the option offers users a means to preserve longer chat histories.

The update marks a pivotal moment for Snapchat, renowned for its disappearing message premise, especially popular among younger demographics. Retaining this focus has been pivotal to Snapchat’s identity, but the shift suggests a broader strategy aimed at diversifying its user base.

This strategy may appeal particularly to older demographics, potentially extending Snapchat’s relevance as users age. By emulating features of conventional messaging platforms, Snapchat seeks to enhance its appeal and broaden its reach.

Yet, the introduction of message retention poses questions about Snapchat’s uniqueness. While addressing user demands, the risk of diluting Snapchat’s distinctiveness looms large.

As Snapchat ventures into uncharted territory, the outcome of this experiment remains uncertain. Will message retention propel Snapchat to new heights, or will it compromise the platform’s uniqueness?

Only time will tell.

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Catering to specific audience boosts your business, says accountant turned coach



Catering to specific audience boosts your business, says accountant turned coach

While it is tempting to try to appeal to a broad audience, the founder of alcohol-free coaching service Just the Tonic, Sandra Parker, believes the best thing you can do for your business is focus on your niche. Here’s how she did just that.

When running a business, reaching out to as many clients as possible can be tempting. But it also risks making your marketing “too generic,” warns Sandra Parker, the founder of Just The Tonic Coaching.

“From the very start of my business, I knew exactly who I could help and who I couldn’t,” Parker told My Biggest Lessons.

Parker struggled with alcohol dependence as a young professional. Today, her business targets high-achieving individuals who face challenges similar to those she had early in her career.

“I understand their frustrations, I understand their fears, and I understand their coping mechanisms and the stories they’re telling themselves,” Parker said. “Because of that, I’m able to market very effectively, to speak in a language that they understand, and am able to reach them.” 

“I believe that it’s really important that you know exactly who your customer or your client is, and you target them, and you resist the temptation to make your marketing too generic to try and reach everyone,” she explained.

“If you speak specifically to your target clients, you will reach them, and I believe that’s the way that you’re going to be more successful.

Watch the video for more of Sandra Parker’s biggest lessons.

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