5/16. The U.S. Court of Appeals (5thCir) issued its opinion [13 pages in PDF] in Doe v. MySpace, affirming the District Court's dismissal of the complaint pursuant to Section 230.

While the 5th Circuit's willingness to apply Section 230 may be viewed as a victory for internet based activities, it should be noted that the opinion, without referencing the 9th Circuit's opinion in the Roommates.com case, stated that it did not decide questions regarding whether any content creation by MySpace would deprive it of Section 230 immunity. Hence, it is possible that the 5th Circuit, in a later opinion, will follow the 9th Circuit.

Background. A 13 year old individual identified in the opinion as Julie Doe created an online profile on the social networking web site named MySpace, which is now owned by News Corporation. Myspace only allows people aged 14 and above to create profiles.

However, people, such as this Julie Doe, lie about their ages. MySpace's web site is also configured to limit the information that is displayed in profiles of persons aged 14 and 15. Julie Doe claimed she was 18.

She met through MySpace a 19 year old named Pete Solis, who is not a party to this appeal. They later met in person, and he sexually abused her.

Proceedings Below. Julie Doe's mother, who is identified in the opinion as Jane Doe, filed a complaint in a trial court of the state of Texas against MySpace, News Corporation, and Solis. She alleged sexual abuse by Solis. She also alleged fraud, negligent misrepresentation, negligence, and gross negligence by MySpace.

Doe later moved for nonsuit (a procedure under which the complaint is dismissed without adjudication on the merits), which was granted. She filed another complaint, not naming Solis as a defendant, in a trial court of the state of New York.

She alleged, among other things, that MySpace "owed a legal duty to 14-year-old Julie to institute and enforce appropriate security measures and policies that would substantially decrease the likelihood of danger and harm".

MySpace removed the action to the U.S. District Court (SDNY), and moved for a change of venue to the U.S. District Court (WDTex), which motion was granted.

MySpace then moved to dismiss based upon the immunity provision of 47 U.S.C. § 230, and Texas common law. The District Court granted the motion to dismiss the claims for negligence and gross negligence. Jane Doe withdrew her other claims. Jane Doe then brought the present appeal.

Statute. 47 U.S.C. § 230 provides certain immunity for an "interactive computer service".

The key subsection, §230(c)(1), provides that "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".

Subsection 230(d)(3) provides that "Nothing in this section shall be construed to prevent any State from enforcing any State law that is consistent with this section. No cause of action may be brought and no liability may be imposed under any State or local law that is inconsistent with this section."

Court of Appeals. The Court of Appeals affirmed, holding that Section 230 immunizes MySpace from the negligence claims.

The Court of Appeals cited and relied upon the long series of cases extending Section 230 to a wide range of web based service providers.

However, it did not cite the one case that defies this line of precedent, and the language and purpose of Section 230, the 9th Circuit's opinion in the Roommates.com case.

The Court wrote that "Parties complaining that they were harmed by a Web site's publication of user-generated content have recourse; they may sue the third-party user who generated the content, but not the interactive computer service that enabled them to publish the content online."

The Court of Appeals rejected the argument of Jane Doe that her claims did not attempt to treat MySpace as a "publisher", and that therefore, Section 230 does not immunize MySpace. It wrote that MySpace published the communications of Solis, and that Doe now seeks to hold MySpace liable as a result of those publications.

The Court of Appeals also rejected the argument of Jane Doe that MySpace created and selected some of the content, and therefore is not entitled to Section 230 immunity. The Court also rejected the argument that MySpace's search function makes it an "information content provider". The Court of Appeals first suggested that the record in this case does not support these arguments, but ultimately ruled that Doe is barred from making these arguments because she did not raise them until the appeal.

The next plaintiff in the 5th Circuit who introduces evidence into the trial court record, and raises this argument in the trial court, will be free to advance this argument on appeal.

The Court of Appeals concluded in the present case as follows: "We therefore hold, without considering the Does’ content-creation argument, that their negligence and gross negligence claims are barred by the CDA, which prohibits claims against Web-based interactive computer services based on their publication of third-party content. 47 U.S.C. § 230(c)(1), (e)(3). Because we affirm the district court based upon the application of § 230(c)(1), there is no need to apply § 230(c)(2), or to assess the viability of the Does’ claims under Texas common law in the absence of the CDA."

Roommates.com. It should be noted that these theories that interactive computer service providers are also content providers, and that search functions are not immune, are what the 9th Circuit seized upon in its aberrant opinion in the Roommates.com case.

Last month, an en banc panel of the U.S. Court of Appeals (9thCir) issued its 8-3 opinion [54 pages in PDF] in FHCSFV v. Roommates.com. See, story titled "En Banc 9th Circuit Panel Rejects Section 230 Immunity in Roommates.com Case" in TLJ Daily E-Mail Alert No. 1,741, April 2, 2008.

The majority held, as did the three judge panel, that an interactive computer service, such as Roommates.com, can be held liable for the speech of users, despite language to the contrary in Section 230. Moreover, the majority held that the web site's search and e-mail notification functions have no immunity.

The 9th Circuit opined that because Roommates.com users provide information in response to an online questionnaire written by Roommates.com, this causes or induces the users to make statements, and hence, makes Roommates.com a content creator.

Search functions, e-mail services, and requesting users to supply answers to certain questions are an integral part of most interactive computers services. The approach of the 9th Circuit, if followed and extended by other courts, threatens to undermine Section 230 immunity. This could result in new state regulation, and a torrent of libel, negligence, and other tort litigation against web site operators.

This case is Jane Doe v. Myspace, Inc. and News Corporation, U.S. Court of Appeals for the 5th Circuit, App. Ct. No. 07-50345, an appeal from the U.S. District Court for the for the Western District of Texas. Judge Edith Clement wrote opinion of the Court of Appeals, in which Judges Garwood and Elrod joined.

5/14. Rep. Adam Schiff (D-CA) and other introduced HR 6060 [LOC | WW], the "Identity Theft Enforcement and Restitution Act of 2008". This bill does contain provisions related to identity theft. However, more of the bill addresses 18 U.S.C. § 1030, the computer hacking statute. This bill would affect activities other than identity theft. It would also affect both criminal prosecutions and civil actions.

On November 16, 2007, the Senate passed S 2168 [LOC | WW], the "Identity Theft Enforcement and Restitution Act of 2007 ", sponsored by Sen. Patrick Leahy (D-VT) and Sen. Arlen Specter (R-PA). S 2168 and HR 6060 are substantially identical.

Rep. Schiff (at right) stated in a release that "Criminals are increasingly using new technologies to prey upon their victims ... As they adapt to these new opportunities to defraud consumers, we must develop better ways to track down the perpetrators and put them away. This legislation will help protect American consumers and businesses from the costly effects of cyber crime and identity theft.”

Rep. Steve Chabot (R-IN), a cosponsor of the bill, stated in this release that "Cyber-criminals are becoming increasingly more tech-savy and aggressive, which raises the stakes for consumers and businesses ... Statistics released by the FBI and industry experts reveal that as many as 10 million computers are under the control of someone other than the owner. This is a serious problem and current law must be updated so we can deal with the sophistication of these crimes."

Bill Summary. Section 1 of the bill contains its title.

Section 2 of the bill would provide for restitution to identity theft victims.

Section 3 of the bill would add to the predicate offenses for aggravated identity theft.

Section 4 of the bill would delete from Subsection 1030(a)(2)(C) the "interstate or foreign communication" requirement.

That is, if this bill is enacted, the statute would provide that "(a) Whoever ... (2) intentionally accesses a computer without authorization or exceeds authorized access, and thereby obtains ...(C) information from any protected computer ... shall be punished".

Spyware, Hacking and Keyloggers. Section 5 of the bill is titled "Malicious spyware, hacking and keyloggers". Although, the terms "spyware" and "keyloggers" appear in neither Section 1030 as currently written, nor as it would read after revision by this bill.

Currently, subsection 1030(a)(5)(A) lists three types of acts, while subsection 1030(a)(5)(B) enumerates various types of injuries that might be caused by these acts. Currently, there is a criminal violation of subsection 1030(a)(5) only if there is both an act under subsection (A) and an injury listed in subsection (B) that was caused by the act.

This bill would eliminate subsection (B). However, the bill would add similar language to the sentencing section of the statute, so that the injury caused by the act would be relevant to the sentence, and hence the offense's classification as either felony or misdemeanor, but would not be an element of the offense.

The three prohibited acts under subsection (a)(5) currently are "knowingly causes the transmission of a program, information, code, or command, and as a result of such conduct, intentionally causes damage without authorization, to a protected computer", "intentionally accesses a protected computer without authorization, and as a result of such conduct, recklessly causes damage" and "intentionally accesses a protected computer without authorization, and as a result of such conduct, causes damage". The bill would, in the third item, replace "damage" with "damage and loss".

The effects of Section 5 of the bill would be to make it easier for prosecutors to bring criminal actions for variety have hacking activities, including use of malicious spyware and keyloggers. It would also make it easier for civil litigants to obtain judicial relief for the same sort of conduct.

It would also sweep within the scope of the statute certain non-malicious conduct that individuals may not understand to be prohibited, for example, in the context of employees accessing the computers of their employers.

Cyber Extortion. Section 6 of the bill would rewrite the cyber extortion subsection. Currently, subsection 1030(a)(7) provides that "(a) Whoever ... (7) with intent to extort from any person any money or other thing of value, transmits in interstate or foreign commerce any communication containing any threat to cause damage to a protected computer ... shall be punished".

The bill would maintain the clause "threat to cause damage to a protected computer", and add two acts that would also constitute extortion under this subsection.

First, it would add this: "threat to obtain information from a protected computer without authorization or in excess of authorization or to impair the confidentiality of information obtained from a protected computer without authorization or by exceeding authorized access".

Second, it would add this: "demand or request for money or other thing of value in relation to damage to a protected computer, where such damage was caused to facilitate the extortion". Thus, if a person were to access a computer without authorization, damage the computer, and then demand payment to fix it, that too would be cyber extortion.

Conspiracy. Currently, subsection 1030(b) provides that "Whoever attempts to commit an offense under subsection (a) ... shall be punished ...".

Section 7 of this bill would add to this whoever "conspires to commit" an offense under subsection (a).

Interstate Commerce and Communications. Section 8 of the bill would amend the definition of "protected computer". Currently, a "protected computer" is one used by the federal government, a financial institution, or any other computer "which is used in interstate or foreign commerce or communication".

This bill would change this final clause to "which is used or affecting".

See, also Section 4 of the bill. These two sections would deprive defendants of the defense that since both the defendant and the accessed computer were located in the same state, their actions cannot constitute a violation of Section 1030.

Forfeiture of Property Used in Section 1030 Violations. Section 9 of the bill would add a new subsection to Section 1030 providing for forfeiture of property used in Section 1030 criminal violations.

Finally, Section 10 of the bill gives directives to the U.S. Sentencing Commission.

The bill is cosponsored by Rep. Chabot, Rep. Rahm Emanuel (D-IL), and Rep. Chris Murphy (D-CT). It was referred to the House Judiciary Committee (HJC). Rep. Schiff and Rep. Chabot are members.

5/18. Microsoft announced in a release that "In light of developments since the withdrawal of the Microsoft proposal to acquire Yahoo! Inc., Microsoft announced that it is continuing to explore and pursue its alternatives to improve and expand its online services and advertising business."

Last week Carl Icahn announced that he is leading a proxy fight to replace the current Yahoo board of directors with one that would negotiate with Microsoft. See, story titled "Icahn Announces Proxy Fight to Elect Yahoo Board that will Negotiate with Microsoft" in TLJ Daily E-Mail Alert No. 1,768, May 16, 2008.

Microsoft's release continues that it "is considering and has raised with Yahoo! an alternative that would involve a transaction with Yahoo! but not an acquisition of all of Yahoo! Microsoft is not proposing to make a new bid to acquire all of Yahoo! at this time, but reserves the right to reconsider that alternative depending on future developments and discussions that may take place with Yahoo! or discussions with shareholders of Yahoo! or Microsoft or with other third parties."

Yahoo responded in its own release that "Yahoo! has confirmed with Microsoft that it is not interested in pursuing an acquisition of all of Yahoo! at this time. Yahoo! and its Board of Directors continue to consider a number of value maximizing strategic alternatives for Yahoo!, and we remain open to pursuing any transaction which is in the best interest of our stockholders. Yahoo!'s Board of Directors will evaluate each of our alternatives, including any Microsoft proposal, consistent with its fiduciary duties, with a focus on maximizing stockholder value." See also, same statement filed with the Securities and Exchange Commission (SEC).

The first sentence of the first paragraph of the story titled "En Banc Panel of 9th Circuit to Hear Sprint v. San Diego" in TLJ Daily E-Mail Alert No. 1,768, May 16, 2008, contained an incorrect hyperlink for the May 14, 2008, order [2 pages in PDF] of the U.S. Court Appeals (9thCir). The incorrect hyperlink directed readers to an earlier order of the Court.

The House will meet at 10:30 AM for morning hour debate, and at 12:00 NOON for legislative business. Rep. Hoyer's schedule for the week of May 19 states that "no votes are expected in the House. The agenda for the week already includes 55 items, the majority of which are resolutions, to be considered under suspension of the rules. The agenda for the week includes HR 752 [LOC | WW], the "Federal Electronic Equipment Donation Act of 2007" and S 2168 [LOC | WW], the "Identity Theft Enforcement and Restitution Act of 2007".

The Senate will meet at 2:00 PM.

9:00 AM - 12:45 PM. The Federal Communications Commission's (FCC) Public Safety and Homeland Security Bureau will host an event titled "Promoting an Effective Emergency Alert System on the Road to a Next Generation EAS". The FCC will webcast the event. Location: FCC, Commission Meeting Room, TW-C305, 445 12th St., SW.

Extended deadline to submit reply comments to the Federal Communications Commission (FCC) in response to it Notice of Proposed Rulemaking (NPRM) regarding the Recommended Decision of the Federal State Joint Board on Universal Service, released on November 20, 2007, regarding comprehensive reform of high cost universal service taxes and subsidies. The FCC adopted this NPRM on January 15, 2008, and released the text on January 29, 2008. It is FCC 08-02 in WC Docket No. 05-337 and CC Docket No. 96-45. See, original notice in the Federal Register, March 4, 2008, Vol. 73, No. 43, at Pages 11587-11591. See also, notice [PDF] of extension (DA 08-674).

Extended deadline to submit reply comments to the Federal Communications Commission (FCC) in response to it Notice of Proposed Rulemaking (NPRM) regarding the use of reverse auctions to determine the amount of high cost universal service subsidies provided to eligible telecommunications carriers serving rural, insular, and high cost areas. The FCC adopted this NPRM on January 9, 2008, and released the text on January 29, 2008. It is FCC 08-05 in WC Docket No. 05-337 and CC Docket No. 96-45. See, original notice in the Federal Register, March 4, 2008, Vol. 73, No. 43, at Pages 11591-11602. See also, notice [PDF] of extension (DA 08-674).

Extended deadline to submit reply comments to the Federal Communications Commission (FCC) in response to its Notice of Proposed Rulemaking (NPRM) regarding the FCC's rules governing the amount of high cost universal service subsidies provided to competitive eligible telecommunications carriers (ETCs). This NPRM also tentatively concludes that the FCC should eliminate the existing identical support rule, which is also known as the equal support rule. The FCC adopted this NPRM on January 9, 2008, and released the text on January 29, 2008. It is FCC 08-04 in WC Docket No. 05-337 and CC Docket No. 96-45. See, original notice in the Federal Register, March 4, 2008, Vol. 73, No. 43, at Pages 11580-11587. See also, notice [PDF] of extension (DA 08-674).

The House will meet at 9:00 AM for morning hour debate, and at 10:00 AM for legislative business. See, Rep. Hoyer's schedule for the week of May 19.

10:00 AM. The Senate Judiciary Committee's (SJC) Subcommittee on Human Rights and the Law will hold a hearing titled "Global Internet Freedom: Corporate Responsibility and the Rule of Law". The witnesses will Nicole Wong (Deputy General Counsel of Google), Michael Samway (Deputy General Counsel of Yahoo), Mark Chandler (General Counsel of Cisco Systems), Arvind Ganesan (Human Rights Watch), and Shiyu Zhou (Global Internet Freedom Consortium). Sen. Richard Durbin (D-IL) will preside. See, notice. Location: Room 226, Dirksen Building.

10:00 AM - 4:15 PM. The U.S.-China Economic and Security Review Commission will hold a hearing titled "China's Proliferation Practices and the Development of its Cyber and Space Warfare Capabilities". See, notice in the Federal Register, April 28, 2008, Vol. 73, No. 82, at Pages 23005-23006. Location: Room 562, Dirksen Building, Capitol Hill.

12:15 - 1:30 PM. The Federal Communications Bar Association's (FCBA) Wireline and International Practice Committees will host a brown bag lunch titled "Functional Separation proposals under the European Commission review of the European Union’s Framework Directive". The speakers may include Sheba Chacko (BT), Wolfgang Jakubek (Deutsche Telecom), Scott Harris (Harris Wiltshire & Grannis), and Don Stockdale (FCC). For more information, contact Nick Alexander at Nicholas dot Alexander at fcc dot gov. Location: Akin Gump, 1333 New Hampshire Ave, NW.

The House will meet at 10:00 AM for legislative business. See, Rep. Hoyer's schedule for the week of May 19.

10:00 AM. The House Education and Labor Committee will hold a hearing titled "The National Mathematics Advisory Panel Report: Foundations for Success". Location: Room 2175, Rayburn Building.

10:00 AM. The Securities and Exchange Commission (SEC) will meet. The agenda states that the SEC "will consider whether to propose amendments to provide for mutual fund risk/return summary information to be filed with the Commission in interactive data format". Location: SEC, Room L-002, 100 F St., NE.

11:00 AM. The Senate Homeland Security and Governmental Affairs Committee will hold a business meeting to consider the nomination of Paul Schneider to be Deputy Secretary of the Department of Homeland Security (DHS). See, notice. Location: Room S-216, Capitol Building.

12:30 PM. The Federal Communications Bar Association's (FCBA) Young Lawyers Committee will hold a brown bag lunch to elect officers and plan. E-mail nominations to Chris Fedeli at chrisfedeli at dwt dot com and Tarah Grant at tsgrant at hhlaw dot com by Friday, May 9, 2008. See, notice online registration page. Location: Hogan & Hartson, 1st floor litigation center, 555 13th St., NW.

1:30 PM. The House Judiciary Committee's (HJC) Subcommittee on Subcommittee on Crime, Terrorism, and Homeland Security will hold a hearing titled "The FBI Whistleblowers: Exposing Corruption and Retaliation Inside the Bureau - FBI Counterterrorism Agent". This hearing will be webcast by the HJC. See, notice. Location: Room 2141, Rayburn Building.

? 3:00 PM. The House Judiciary Committee (HJC) may hold a closed meeting regarding HR 5889 [LOC | WW], the "Orphan Works Act of 2008". Location: Room 2226, Rayburn Building.

Day one of a two day closed meeting of the Department of Defense's (DOD) Defense Science Board regarding undisclosed topics. See, notice in the Federal Register, April 23, 2008, Vol. 73, No. 79, at Pages 21919-21920. Location: Pentagon, Arlington, VA.

The House will meet at 10:00 AM for legislative business. See, Rep. Hoyer's schedule for the week of May 19.

9:00 - 10:30 AM. The New America Foundation (NAF) will host an event titled "Google Unwired: Expanding Broadband Access and Allocating Spectrum More Efficiently". The speakers will be Larry Page (Google) and Michael Calabrese (NAF). See, notice and registration page. Breakfast will be provided. Location: Ronald Reagan Building, Atrium Ballroom, 1300 Pennsylvania Ave., NW.

10:00 AM. The Senate Judiciary Committee (SJC) may hold an executive business meeting. The agenda includes consideration of the nomination of Elisebeth Cook (to be Assistant Attorney General in charge of the Office of Legal Policy), William Lawrence (U.S. District Court for the Southern District of Indiana), and Murray Snow (U.S.D.C., District of Arizona). See, notice. The SJC rarely follows its published agendas. Location: Room 226, Dirksen Building.

10:00 AM - 12:00 PM. The House Science Committee's (HSC) Subcommittee on Investigation and Oversight will hold a hearing titled "American Decline or Renewal? -- Globalizing Jobs and Technology". The witnesses will be Ralph Gomory (NYU Stern School of Business), Margaret Blair (Vanderbilt University Law School), Bruce Scott (Harvard Business School), James Copland (Copland Fabrics), Joseph Fehsenfeld (Midwest Printed Circuit Service), and Wes Jurey (Arlington Chamber of Commerce, Arlington, Texas). Location: Room 2318, Rayburn Building.

10:00 AM. The Senate Finance Committee (SFC) will hold a hearing on S 1919 [LOC | WW], the "Trade Enforcement Act of 2007", a bill to amend the Trade Act of 1974. It would require the Office of the U.S. Trade Representative to report to the Congress on trade enforcement priorities and actions. It would also create a "WTO Dispute Settlement Review Commission". It also contains provisions specific to the People's Republic of China. See, notice. Location: Room 215, Dirksen Building.

12:15 - 1:30 PM. The Federal Communications Commission (FCC) will hold an event titled "FCC Wireless Legal Advisors Discuss Recent and Upcoming Matters". The speakers may include Aaron Goldberger (FCC Chairman Kevin Martin assistant), Bruce Gottlieb (FCC Commissioner Michael Copps assistant), Renée Crittendon (FCC Commissioner Jonathan Adelstein assistant), Wayne Leighton (FCC Commissioner Deborah Tate assistant), and Angela Giancarlo (FCC Commissioner Robert McDowell assistant). Lunch will be served. The price to attend is $15. See, notice and registration page. The Federal Communications Bar Association's (FCBA) web site states that this is an event of the FCBA's Wireless Practice Committee. Location: Sidley Austin, 6th floor, 1501 K St., NW.

Day two of a two day closed meeting of the Department of Defense's (DOD) Defense Science Board regarding undisclosed topics. See, notice in the Federal Register, April 23, 2008, Vol. 73, No. 79, at Pages 21919-21920. Location: Pentagon, Arlington, VA.

Deadline to submit initial comments to the Federal Communications Commission's (FCC) Consumer & Governmental Affairs Bureau in response to its Public Notice regarding the request for clarification filed by Hawk Relay that internet protocol speech to speech (IPSTS) is a form of Telecommunications Relay Service (TRS). This item is DA 08-292 in CG Docket No. 08-15. See, notice in the Federal Register, April 7, 2008, Vol. 73, No. 67, at Page 18796.

Deadline to submit initial comments to the Federal Communications Commission (FCC) in response to the Media Bureau's public notice (DA 08-752) regarding changes to its annual reporting forms that request certain employee data from multichannel video programming distributors (FCC Form 395-A) and broadcasters (FCC Form 395-B). See, notice in the Federal Register, April 21, 2008, Vol. 73, No. 77, at Pages 21346-21347.

Extended deadline for voting equipment manufacturers to submit requests and executed letters of understanding to the National Institute of Standards and Technology (NIST). See, notice in the Federal Register, April 22, 2008, Vol. 73, No. 78, at Pages 21590-21591.

Rep. Hoyer's schedule for the week of May 19 states that "no votes are expected in the House".

Deadline to submit reply comments to the Federal Communications Commission's (FCC) Consumer and Governmental Affairs Bureau (CGAB) regarding the National Exchange Carriers Association's (NECA) proposed compensation rates for interstate traditional TRS, interstate speech-to-speech (STS), interstate captioned telephone service (CTS) and interstate and intrastate internet protocol captioned telephone service (IP CTS), interstate and intrastate IP relay; and interstate and intrastate video relay service (VRS). See, notice in the Federal Register, May 12, 2008, Vol. 73, No. 92, at Page 26992-26993. This proceeding is CG Docket No. 03-123.

Deadline to submit comments to the Internet Corporation for Assigned Names and Numbers (ICANN) regarding proposed changes [PDF] to the December 8, 2006, .ORG Registry Agreement. See, ICANN notice.

Memorial Day. See, Office of Personnel Management's (OPM) list of 2008 federal holidays.

Day one of the House Memorial Day recess. See, Rep. Hoyer's 2008 calendar [4.25 MB PDF].

The Senate will begin its Memorial Day recess. See, Senate 2008 calendar.

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