WorldStarHipHop Gets Section 230 Dismissal–Eizenga v. MediaLab

The court describes the video in question (as alleged):

an anonymous social media account and online “persona” known as Rain Drops Media (“Rain Drops”) published a defamatory video falsely suggesting that Eizenga was an abusive partner who battered Monroe Capri Bryant (“Bryant”), a young social media influencer. The video in question consists of a collage of other social media posts and clips from Bryant’s live-stream featuring Plaintiff and Bryant together along with a caption that reads, “Woman was punched and assaulted by her boyfriend, she claims he still loves her and insists they’re ‘good’ . . . .” In the video, one of Bryant’s eyes is severely bruised, and Plaintiff can be seen attempting to kiss Bryant on the temple. The video has been viewed roughly four million times on the social media platform X…

WorldStar reposted Rain Drops’ video to its social media accounts (including
Facebook, Instagram, and worldstarhiphop.com) with a slightly modified caption that now read: “CYCLE OF ABUSE: Woman With A Black Eye Goes Live With Boyfriend Who Allegedly Punched Her, Insisting ‘He Loves Me’ And ‘We’re Good’ As He Kisses Her On Camera.” WorldStar also “tagged” the video with three identifiers: (1) “domestic violence,” (2) “Relationships,” and (3) “TikTok.” Plaintiff does not allege that Defendant created or otherwise altered Rain Drops’ video.

WorldStarHipHop defeats the lawsuit per Section 230.

ICS Provider. The court summarizes the general rule: “websites that allow third-party users to submit or upload content are providers of internet computer services.” WorldStarHipHop qualifes:

Plaintiff does not allege that Defendant independently generates any content whatsoever. Rather, Plaintiff alleges that Defendant merely reposted the challenged content without editing the video itself

The court seems to be conflating this factor with the other two. Plus, if WorldStarHipHop is posting to third-party social media like Facebook and Instagram, it might be more accurately characterized as an ICS user, not provider.

Publisher/Speaker Claim. Plaintiff conceded this.

Third-Party Content. The court quickly jumps to the Roommates.com exceptions. It defines the rule as “a website operator may be held liable for third-party content where (1) it “substantively alters” the content and where (2) the substantive alteration is “directly involved in the alleged illegality.”” The court continues:

The bar for “substantive alteration” is high. To start, the test requires something above and beyond the “exercise of a publisher’s traditional editorial functions—such as deciding whether to publish, withdraw, postpone or alter content.” Nor is it enough for a plaintiff to allege that a defendant promoted content through the use or creation of algorithms, tags, video thumbnails, summaries, posts, or animations.

WorldStarHipHop doesn’t meet these standards:

Plaintiff alleges that Defendant made just three changes to Rain Drops’ original video: (1) adding “CYCLE OF ABUSE” to the caption, (2) adding “allegedly” to the caption, and (3) tagging the video with a “domestic abuse” identifier. Those minor changes—none of which altered the video itself—fall far short of the allegations required to make out substantive alteration. [cite to Doe v. Fenix and L.H. v. Marriott.]…The minor, paratextual modifications at issue here fall far short of the more substantial alterations courts found wanting in Fenix Int’l and L.H….

Defendant created nothing. It reposted a preexisting video and adopted a preexisting caption almost word-for-word. The addition of the leading phrase “CYCLE OF ABUSE” and the “domestic violence” tag at most “augment” or “develop[] by inference” the alleged illegality already at issue in the original video.

The court distinguishes the problematic Doe #1 v. MG Freesites ruling, saying that the MG Freesites court excluded CSAM from the definition of “information” (an obviously wrong conclusion); plus “the allegations at play in MG Freesites were much more favorable to the plaintiff than what’s on display here. At most, Plaintiff has alleged that Defendant added the “domestic violence” tag to Rain Drops’ video, but none of the other types of allegations from MG Freesites are present here.”

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I don’t think all courts would treat the WorldStarHipHop-added headline and tags as third-party content. This is a highly confused area of Section 230 jurisprudence. A court could have said that the headline and tags weren’t an integral part of the video (they are metadata) and thus don’t necessarily need the same legal treatment as the video. A court also could say that even small semantic differences between the original headline and video tags and WorldStarHipHop’s headline and tags create new meaning added by WorldStarHipHop.

Also, it’s weird that the court appears to gloss over WorldStarHipHop’s download-and-reupload of the Rain Drop’s video. (The court never says that WorldStarHipHop only links to or embeds the third-party video; that might change the case’s complexion substantially). I have repeatedly blogged about Section 230’s ambiguities from treating downloaded-and-reuploaded content as “information provided by another information content provider.” (See, e.g., the D’Alonzo case 20 years ago). In light of Section 230’s downward trendlines, it’s a little jarring to see the court discuss WorldStarHipHop taking all of these actions itself and still concluding that everything remained third-party content.

(WorldStarHipHop would also raise copyright concerns with an download/reupload, but this plaintiff would not be the right enforcer of that issue).

Case Citation: Eizenga v. MediaLab.Ai Inc., 2026 U.S. Dist. LEXIS 103543 (May 11, 2026). Also of interest: my 2012 post on Scott v. WorldStarHipHop.