How the Sixth Circuit Took the Pep Out of a Former Cincinnati Ben-Gal Cheerleader

The Sixth Circuit recently considered whether the Communications Decency Act of 1996 (CDA) bars state-law defamation claims in Jones v. Dirty World Entertainment Recordings, LLC, Case No. 13-5946 (6th Cir. June 16, 2014). The court answered in the affirmative and adopted the “material contribution” test to evaluate the scope of immunity conferred by section 230 of the CDA.