Marshall's Locksmith Serv. Inc. v. Google LLC
Issue
Whether § 230 bars claims against search and directory platforms for listing and promoting fraudulent locksmith businesses that deceived customers with bait-and-switch pricing.
What Happened
A class of consumers sued Google, Yelp, and HomeAdvisor, alleging the platforms listed and promoted scam locksmiths who advertised low prices online but then charged inflated amounts on arrival. Plaintiffs argued the platforms profited from the fraudulent listings and should be liable for consumer protection violations. The D.C. Circuit affirmed dismissal, holding § 230 barred the claims: the platforms were publishers of third-party business listings and were not responsible for the fraudulent content or conduct of the locksmiths who advertised on them.
Why It Matters
Applied § 230 to a marketplace fraud context, holding that listing businesses and users who later engage in fraud does not strip a platform of publisher immunity. Consistent with the broad reading of § 230 as immunizing platforms for harms traced back to the conduct of third-party users or service providers listed on the platform.
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