Doe v. Grindr, Inc.
Issue
Whether § 230 bars claims arising from Grindr's design features and failure to implement safety measures that allegedly enabled harassment and assault of platform users.
What Happened
In a significant Ninth Circuit reconsideration of the Grindr platform's liability, the court addressed claims that Grindr's design choices — including its geolocation features and lack of effective identity verification — made it a tool for stalking and assault. The Ninth Circuit analyzed whether the design-defect framework from Lemmon v. Snap applied to the Grindr context, and whether § 230 barred claims targeting the platform's own architectural choices rather than its publication of third-party content.
Why It Matters
Represents the Ninth Circuit's return to the Grindr platform years after Herrick v. Grindr in the Second Circuit. The case tests the reach of the Lemmon design-defect doctrine in a non-speed-filter context — specifically, whether geolocation and identity features of a dating app constitute the platform's own product conduct. The interplay between this Ninth Circuit decision and Herrick in the Second Circuit reflects the ongoing circuit-level divergence on platform liability for design features that enable offline harm.
Related Filings
Other proceedings in the same litigation tracked by this monitor.
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