*Result*: Anderson, Algorithms, and Section 230 After NetChoice: The Risk of a New Moderator's Dilemma.

*The article focuses on recent legal developments concerning the intersection of content moderation algorithms, Section 230 of the Communications Decency Act, and First Amendment protections, particularly following the Supreme Court’s 2021 NetChoice decisions. It highlights a circuit split where the Second Circuit in Force v. Facebook upheld Section 230 immunity for algorithmic content moderation, while the Third Circuit in Anderson v. TikTok denied such protection, raising concerns about increased liability for platforms using recommendation algorithms. The article discusses potential consequences of denying Section 230 protections to algorithms, including chilling effects on online expression, increased litigation costs that may disadvantage smaller platforms, and negative impacts on AI innovation. It concludes that legislative attempts to clarify Section 230’s scope may create further problems, and that Supreme Court intervention is likely necessary to resolve these issues and preserve the balance between free speech, platform liability, and technological development. [Extracted from the article]*