Internet service providers (“ISPs”) generally enjoy an absolute immunity with respect to content provided by others if they play no role in gathering or editing that content. The narrow exceptions concern federal criminal liability and intellectual property infringement. When those concerns were not implicated, the courts have for many years interpreted Section 230 of the Communications Decency Act of 1996, 47 U.S.C. § 230, broadly and have used it to protect ISPs that refused to take down even clearly libelous materials. However, the sense of comfort that an ISP need not concern itself with the content of materials posted by others has recently been called into question by an Illinois appeals court, which held that an employer could be found liable for failing to take down an employee’s threats made to a third party. The court concluded that irrespective of Section 230, the employer could be found liable for negligent supervision because its duty to supervise its employees “is distinct from any conduct like editing, monitoring or removing offensive content published on the Internet.” The case is Lansing v. Southwest Airlines Co., 212 Ill. App. (1st) 101164 (Ill. Ct. App. June 8, 2012).