The U.S. District Court for the District of Colorado found, in General Steel Domestic Sales, LLC v. Chumley, that a seller of pre-engineered steel buildings and its CEO were not entitled to immunity under Section 230 of the Communications Decency Act (CDA) for their derogatory Internet postings about a competitor even though those postings consisted of quotations or summaries of information previously posted elsewhere by third parties.  The court reasoned that the defendants’ selection of the quotations and summaries contributed to the allegedly defamatory character of the content, and therefore was not covered by CDA immunity.  Courts have struggled to determine when such editorial decisions cross the line from immune editing into non-immune “development” of content, and this decision provides a window into the sorts of factors that can cause a web publisher to forfeit its CDA immunity.