This article analyzes how the anti-discrimination language of Fair Housing Act section 3604 is currently out of reach for people being discriminated against online through the exclusionary language of Communications Decency Act section 230(c). The exclusionary language in CDA section 230(c) prevents liability from attaching to interactive computer service providers so long as the interactive computer service provider is not a creator or developer of information. Through the decisions of Zeran, Craigslist, and Roommate, the federal appellate courts created broad shield of immunity for interactive computer service providers, leading to a safe haven for discrimination online. Together the courts and Congress need to act to prevent further discrimination in housing advertisements online.

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