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Timeline timeline/1991-10-29-cubby-v-compuserve-treats-online-service-as-distributor
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Every change to the Cubby v. CompuServe treats an online service as a distributor page: what changed, when it went live, and how it was reviewed.
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ToneBefore “Court shields a non-reviewing online service from liability for third-party content.”
After “Court treats a non-reviewing online service as a distributor, not a publisher, of third-party content.”
Why: "Shields" is a slightly loaded verb that frames the ruling as protective/favorable to the defendant rather than describing the legal holding neutrally. A more neutral phrasing would describe the actual holding, e.g. "Court holds a non-reviewing online service liable only as a distributor" or "Court grants summary judgment to a non-reviewing online service, holding it liable only as a distributor," which matches the frontmatter description already given.