Force v. Facebook, Inc.

[1] The court ruled that the recommender system remains as part of the role of the distributor of the content and not the publisher, since these automated tools were essentially neutral.

Judge Robert Katzman gave a 35-page dissenting opinion in the Force case, stating "Mounting evidence suggests that providers designed their algorithms to drive users toward content and people the users agreed with – and that they have done it too well, nudging susceptible souls ever further down dark paths.

"[4] Katzman's dissent was cited by Judge Clarence Thomas statement in respect of denying certiorari to Malwarebytes, Inc. v. Enigma Software Group USA, LLC.

The Electronic Frontier Foundation filed an amicus curaie brief in the case, arguing for platform immunity.

[5] The court that year also declined to hear Dyroff v. Ultimate Software Group Inc., a related case that cited Force.