When President Clinton signed the Communication Decency Act, online pornography—and not defamation—was the focus of debate. However, in Reno v. American Civil Liberties Union, 521 U.S. 844 (1997), the Supreme Court struck down the pornography provisions, leaving §230’s protections from liability arising from third-party content.

On the other side of the Atlantic, however, the United Kingdom took a very different approach to online defamation. While the average British Parliamentarian may have had little experience of the internet at this time (by 2000, still only approximately one third of Westminster MPs were making use of the email facilities provided to them), concerns were raised about the Internet from early stages.

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