The European Court of Human Rights in Delfi v. Estonia punched a potentially large hole in the immunity from liability of European websites for hosting user-generated content, rejecting arguments that such liability imposes unjustified interference with the right of free expression.  Coupled with the European Court of Justice decision last year in Google Spain on the "right to be forgotten," the Delfi decision appears to put the free speech rights of European online service providers in serious jeopardy, and raises questions about the continuing vitality of Internet service providers’ immunity from liability for user-generated content.