Claims against porn sites dismissed because of Section 230 immunity

Plaintiffs sued several internet pornography companies after they discovered that videos secretly recorded of them while changing in a college locker room had been uploaded online.

Plaintiffs asked the court to hold the defendants liable under several theories, including civil conspiracy, negligent monitoring, and violations of the Trafficking Victims Protection Reauthorization Act (TVPRA).

The court granted summary judgment in favor of defendants.

The court held that Section 230 of the Communications Decency Act shielded the defendants from liability for user-generated content, and plaintiffs failed to show that any of defendants materially contributed to the illegal aspects of the videos. The court also found no evidence of a conspiracy or that defendants met the requirements to be considered beneficiaries of a sex trafficking venture under the TVPRA. Claims against defendants who merely licensed trademarks or placed ads were also rejected due to lack of personal jurisdiction or insufficient evidence of wrongdoing.

Jane Does 1–9 v. Collins Murphy, et al., No. 7:20-cv-00947-DCC, 2025 WL 2533961 (D.S.C. Sept. 3, 2025).