Dyroff v. The Ultimate Software Grp., Inc.

Issue: Whether § 230 bars wrongful death claims against an online community platform whose recommendation features allegedly connected a user with the drug dealer who sold him the heroin that killed him.

Plaintiff's son used WeConnect, an online community for people in substance abuse recovery, to connect with another user who sold him heroin that caused his fatal overdose. Plaintiff alleged that WeConnect's recommendation features — which suggested connections between users based on shared interests — materially contributed to the illegal drug transaction by connecting her son with his dealer. The Ninth Circuit affirmed dismissal, holding that the recommendation features were neutral publisher tools that surfaced user-generated connections; they did not develop or contribute to the illegal content or conduct.

Applied § 230 to algorithmic connection-recommendation features, distinguishing the neutral recommendations in WeConnect from the structured, discriminatory questionnaire in Roommates.com. The case illustrates the line between passive publication of connections (protected) and active development of harmful content (not protected), in a context involving serious offline harm from drug dealing facilitated by the platform.