Angelilli v. Activision Blizzard, Inc., 2025 WL 1181000

Issue: Whether § 230 bars claims that Activision's online gaming platform facilitated harassment and harmful conduct directed at plaintiff through features of its Call of Duty game and matchmaking system.

Plaintiff alleged that Activision's online gaming infrastructure and matchmaking algorithms enabled and amplified severe harassment directed at her through the Call of Duty platform, resulting in serious harm. Activision moved to dismiss on § 230 grounds, arguing the claims were based on third-party user conduct and content. The district court addressed the scope of § 230 in the video game and online gaming platform context, considering whether the platform's design and matchmaking features constituted independent platform conduct or publisher activity.

Part of the emerging litigation testing the scope of § 230 in the online gaming context, where platform design choices about matchmaking, anonymity, and in-game communication systems intersect with severe harassment. Related to the companion decision in the same matter, 2025 WL 1184247.