In Jones v. Dirty World Entertainment Recordings LLC, No. 13-5946 (6th Cir. June 16, 2014), plaintiff was the subject of several posts that were anonymously uploaded to a website that publishes user-generated comments generally targeted at nonpublic figures. In response, plaintiff sued the website and its operator for defamation, prevailing in a jury trial, and obtaining a judgment in her favor for compensatory and punitive damages. On appeal, the Sixth Circuit vacated the judgment and held, as a matter of first impression in that circuit, that plaintiff’s state-law defamation claims were barred by the federal Communications Decency Act of 1996 (CDA). The CDA provides that no provider of an interactive computer service shall be treated as the publisher or speaker of any information provided by another user. The Sixth Circuit followed several other circuits in holding that the CDA thus grants broad immunity to providers of interactive computer services against any liability arising from content created by third parties. The court noted, however, that such immunity is not available if the website operator is responsible, in whole or in part, for the “creation or development” of the content at issue. The court explained that a provider “develops” content for purposes of the CDA if it makes a “material contribution” to the content’s alleged unlawfulness.