Bennett v. Google, LLC
Issue
Whether § 230 bars a defamation claim against Google for autocomplete search suggestions that displayed allegedly defamatory phrases when users began typing the plaintiff's name.
What Happened
Robert Bennett alleged that Google's autocomplete algorithm paired his name with defamatory associations in suggested searches. Bennett argued Google was the author of the autocomplete suggestions because the algorithm generated the phrasing. The D.C. Circuit affirmed dismissal, holding that Google's autocomplete feature was protected by § 230(c)(1) — it was a presentation of information derived from third-party search behavior and content, not Google's own expressive choice. Google did not develop the content suggested in autocomplete; it algorithmically reflected patterns in what others had searched.
Why It Matters
Applied § 230 to search engine autocomplete, holding that algorithmically aggregated suggestions based on third-party search patterns are publisher activity, not independent content creation. Consistent with Force v. Facebook in the Second Circuit on the treatment of algorithmic functions as publisher activity.
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