SC v. Dirty World

Dirty World Entertainment Recordings LLC (Dirty World) and its founder and editor-in-chief, Nik Richie (defendants), operated www.TheDirty.com, a website that published comments, photographs, and videos submitted by users on all topics, including gossip. Richie and his staff chose which submissions to publish, but they did not otherwise alter or edit what was submitted before publishing it. A user submitted a post titled “Nasty Church Girl” alleging that SC (plaintiff) was a slut and had engaged in sexual relations with the user’s boyfriend. Richie published the post without making any changes and included a photograph of SC submitted by the user. Richie also made a negative comment about SC’s appearance below the post. SC worked for a church and was an active member in that church. SC claimed that the information in the post was false and had harmed her, particularly given her connection to her church. SC sued Richie and Dirty World for defamation, invasion of privacy by public disclosure of false facts, invasion of privacy by false light, and intentional infliction of emotional distress. Richie and Dirty World claimed that the federal Communications Decency Act (CDA) gave them immunity from these tort claims because Dirty World was just an interactive service provider that had not created or altered the post.