The U.S. Court of Appeals for the Ninth Circuit has held, in Doe 14 v. Internet Brands, Inc., that a modeling website may be liable for failing to warn users about a rape scheme targeting users of a website owned by Internet Brands, Inc.  The plaintiff may now pursue her claim of negligent failure to warn, which the district court had originally ruled was barred by the immunity provision in Section 230 of the Communications Decency Act (CDA), which protects against claims that treat a website as the publisher or speaker of content provided by third parties.  The Ninth Circuit held that the plaintiff’s “failure to warn claim had nothing to do with Internet Brands’ efforts, or lack thereof, to edit or remove user generated content,” meaning that Internet Brands cannot claim immunity under the CDA.