Anyone have good examples of US law causing platforms (or anyone) to delete content outside the US? I don’t mean platforms doing it bc they think the law of their home country has special authority. US law forcing them to. 1/
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i can think of notable examples of it _not_ being able to do so, to the annoyance of US entities. russian allofmp3 with its dubious "radio" license and vkontakte gaining market share in part due to generous video/audio upload allowances and little regard for the DMCA
aug 30, 2025, 10:19 pm • 1 0 • view
dark net market server seizures outside the US are often conducted in cooperation with US law enforcement, but those aren't exactly legal in other jurisdictions either
aug 30, 2025, 10:23 pm • 1 0 • view
For a copyright case at domain name level check out israel.tv
aug 31, 2025, 4:43 am • 0 0 • view
Natsec export control laws can restrict data transfers. As someone else mentioned, OFAC sanctions could be relevant too. Maybe something related to CFIUS too? Also, child pornography laws would certainly cause platforms to not host that content anywhere, onshore or off, I would think.
aug 31, 2025, 12:28 am • 3 0 • view
Basically, I think it’s more likely that there is content that US corps do not host abroad in the first place, as opposed to having hosted it and then later deleting it, because I think most of the relevant laws probably predate the internet.
aug 31, 2025, 12:29 am • 1 0 • view
I think of US CSAM and (c) as being in the same category: The laws don't say anything about being extra-territorial. But the companies assume that US courts would, perhaps appropriately, assume broader jurisdiction than foreign courts bc this is the place of incorporation/center of decisionmaking.
aug 31, 2025, 5:24 pm • 1 0 • view
The slight difference is that IP reciprocity is governed by treaties, whereas I’m not sure if there are CSAM treaties.
aug 31, 2025, 5:29 pm • 2 0 • view
Yep. We used this and "harmonization" as an excuse when people yelled at Google for going global DMCA takedowns. Then people from countries with shorter copyright duration or different exceptions got mad :)
aug 31, 2025, 5:34 pm • 0 0 • view
You've already mentioned copyright, which is the first thing that popped into my head. The second are US sanctions, esp. against Iran (talked a bit more a couple of years ago IIRC), which have resulted in a bunch of extraterritorial speech restrictions, regardless of whether the extraterritorial
aug 31, 2025, 12:32 am • 1 0 • view
interpretation is correct. This article names many cases: www.eff.org/deeplinks/20... I imagine (and seem to vaguely recall but my brain might just be making things up) accounts terminated (necessarily globally) for similar reasons under criminal law as under sanctions law.
aug 31, 2025, 12:32 am • 0 0 • view
Another article I had saved on the speech-related impacts of sanctions: www.lawfaremedia.org/article/how-... (EU has a Blocking Statute to combat extraterritorial sanctions regimes BTW.) Also makes me curious how §230 and DSA immunities apply to sanctions law. Ban on general monitoring would
aug 31, 2025, 12:32 am • 0 0 • view
suggest intermediaries don't need to seek out accounts of sanctioned entities and instead need to be notified (and then go in on an also kinda banned fact-finding exercise?). (Though I actually don't understand exactly how §230 interacts with criminal law.) While not really a content takedown,
aug 31, 2025, 12:45 am • 1 0 • view
taking away access to (non-public/SNS) intermediary services (like the ICC prosecutor's email account) seems like the same sort of issue, with speech/association-related impacts. Domain name seizures (and similar seizures of property) may also have similar takedown-like effects. But that's probably
aug 31, 2025, 12:45 am • 0 0 • view
beyond the scope of what you're asking. As a bonus, and while on the topic of sanctions, one might wonder how interoperability would work with a sanctioned foreign SNS. Meta's Article 7 DMA reference offer rules out interop sanctioned entities... Doubt that's permissible under the DMA though.
aug 31, 2025, 12:45 am • 1 0 • view
Oooh, that one sounds like a potential hard conflict. If EU law requires interoperating with someone/an entity on the export controls list? I think that's a big deal, like a countries-need-to-sort-that-out level deal. Or if we had all sane countries that would be how this should work.
aug 31, 2025, 5:28 pm • 0 0 • view
Some of those export control laws are criminal, which puts them outside of CDA 230. But also for some the prohibited export can truly be the service itself (not just user content), so it'd be outside 230 for that reason also.
aug 31, 2025, 5:26 pm • 1 0 • view
I think of US CSAM and (c) as being in the same category: The laws don't say anything about being extra-territorial. But the companies assume that US courts would, perhaps appropriately, assume broader jurisdiction than foreign courts bc this is the place of incorporation/center of decisionmaking.
aug 31, 2025, 5:25 pm • 1 0 • view
Domain registration disputes?
aug 31, 2025, 4:26 am • 4 0 • view
Oh you mean for trademark? Good point, I was just thinking of the ICE domain seizures.
aug 31, 2025, 5:29 pm • 2 0 • view
Though there is some level of international agreement on those as I recall.
aug 31, 2025, 5:29 pm • 1 0 • view
Yeah, I was thinking trademark and also stuff like registering a domain to personally harass someone, etc. plus things like domain name seizures for sites engaged in activity that's illegal in the US -- I can't remember what registrar the Silk Road used and whether it was extraterritorial, etc
aug 31, 2025, 5:32 pm • 1 0 • view
I know some of that is treaty-based but my brain is insisting there are some instances of seizures that had their root purely in US law, although fucked if I can get it to cough up specific examples
aug 31, 2025, 5:34 pm • 2 0 • view
Yes, tho struggling to come up with ones that aren't trademark-enabled seizures. Microsoft had a bunch (eg here) www.noticeofpleadings.com/strontium/
aug 31, 2025, 5:39 pm • 4 0 • view
If you go back a lot further you might find some from the original copyright wars, or delisting ISIL sites tho. Don't have any off the top of my head, but those would have been non-trademark cases
aug 31, 2025, 5:41 pm • 3 0 • view
I know there's been a bunch of fraud-and-cybercrime-related one, too
aug 31, 2025, 5:41 pm • 3 0 • view
In the 2010s ICE was doing some messed up domain seizures based on US copyright law (@andrewbridges.bsky.social and @marklemley.bsky.social both represented clients on those), and some CSAM based ones that took down all kinds of other unrelated stuff.
aug 31, 2025, 5:38 pm • 6 2 • view
That one is ungoogle-able because the site was called mooooo.com or maybe mooo.com or moooooooo.com or... something with an indeterminate number of o's.
aug 31, 2025, 5:39 pm • 1 0 • view
This isn't what you're looking for (it's not US law), but GDPR definitely had that impact on US platforms.
aug 30, 2025, 9:30 pm • 2 0 • view
I don't have a case in mind but wondering if there might have been speech impacts from OFAC sanctions?
aug 30, 2025, 9:38 pm • 0 0 • view
Many such cases bsky.app/profile/gate...
aug 31, 2025, 12:46 am • 1 0 • view
Oh good point. Yes, definitely. Last time I looked (forever ago) those or one of the other export control laws had carve-outs for things like news services, but they were very poorly defined.
aug 30, 2025, 9:44 pm • 1 0 • view
And they've grown in scope and use like wildfires (as per Underground Empire), I'd be surprised if there hadn't been an impact. Rumours of OFAC being used against DSA makes it timely too.
aug 30, 2025, 10:01 pm • 0 0 • view
Digital sovereignty for you, Robin. Europe does it in a worse way from the Internet infrastructure level to fight Russian disinformation. I don’t know who is coming up with using “OFAC” against DSA, but one thing to know is that OFAC is an office. You can’t just use it…
aug 31, 2025, 4:38 am • 2 0 • view
I was wondering about this -- do you know if/how much the EU asserted authority to make anyone block RT and Sputnick etc. for users outside of EU territory? @tjmcintyre.com ?
aug 31, 2025, 5:32 pm • 1 0 • view
I know in the immediate aftermath of the invasion and the initial flurry of sanctions, many RT/Sputnick related accounts went offline but I gather many returned in the months afterwards and enforcement is poor.
aug 31, 2025, 5:39 pm • 1 0 • view
They also told platform(s) to block that material, and tried to be quiet about it, and... it was a whole messy thing. x.com/daphnehk/sta...
aug 31, 2025, 5:40 pm • 1 0 • view
Over the summer @alliance4europe.bsky.social published a report focused on X's ongoing content moderation failures of sanctioned russian entities alliance4europe.eu/flagged-and-...
aug 31, 2025, 5:42 pm • 2 0 • view
I don't think we've any visibility into what the Commission did, other than that one email which was uploaded to Lumen. Even that email is ambiguous - search results blocked for "users in the EU" but no such limit for social media restrictions.
aug 31, 2025, 8:25 pm • 2 0 • view
US been trying that with the UK. Or at least the other way around? Trying to get UK and Europe to not apply laws restricting abusive content on internet sites x, meta, etc.
aug 31, 2025, 6:09 pm • 0 0 • view
Yeah, sorry I should have excluded this -- US reaching out and trying to force carriage of content, vs US reaching out and trying to suppress it. Not that the former is not an issue!
aug 31, 2025, 6:10 pm • 1 0 • view
not deletion, but... www.digitaljournal.com/tech-science...
aug 30, 2025, 10:33 pm • 2 0 • view
The Scottish Police force encountered a similar response when they tried to get Microsoft to give them information about where their O365 data would be stored and processed
aug 31, 2025, 6:22 pm • 0 0 • view
Many DMCA cases, probably others as well. The Lumen database contains legal complaints and requests for removal of online materials. You can then see if the site complained about is accessible after the complain --we did that some time ago arxiv.org/pdf/1902.05796
aug 31, 2025, 9:46 am • 0 0 • view
This looks fascinating! Adding it to the open tabs :)
aug 31, 2025, 5:36 pm • 2 0 • view
I think of US CSAM and (c) as being in the same category: The laws don't say anything about being extra-territorial. But the companies assume that US courts would, perhaps appropriately, assume broader jurisdiction than foreign courts bc this is the place of incorporation/center of decisionmaking.
aug 31, 2025, 5:34 pm • 0 0 • view
Very likely. From a quick look I saw DCMA notices arguing that the material is CSAM. May be leveraging the international remit of DCMA, may be easier to produce
aug 31, 2025, 5:56 pm • 0 0 • view
Oh one zillion percent this. A fake DMCA notice is a pretty good calculated risk for non-(c)-holder NCII victims too. (This is NOT legal advice.)
aug 31, 2025, 6:01 pm • 1 0 • view
Well, we all know everyone outside US has their daily experience of what they see online shaped by US law and US norms. I live in Portugal - if i search on Facebook for the state railway company « CP.pt » i get this message « child sex abuse is illegal »
aug 30, 2025, 9:45 pm • 2 0 • view
www.publico.pt/2024/07/12/s...
aug 30, 2025, 9:48 pm • 0 0 • view
I’m sorry, that’s really obnoxious.
aug 30, 2025, 9:52 pm • 2 0 • view
I think there are some copyright cases Marketa Trimble has written about on @ericgoldman.bsky.social’s blog with US courts asserting jurisdiction over foreign platforms. (Summaries or updates very welcome on those!) And I know about ICE’s site-blocking shenanigans in early 2010s. 2/
aug 30, 2025, 9:30 pm • 2 0 • view
And I know that lots of European lawyers 10-ish years older than myself are still pissed about US extra-territorial antitrust claims in the past, but I don’t know of any speech ramifications from those. 3/
aug 30, 2025, 9:32 pm • 4 0 • view
And there are separate fights about cross border law enforcement demands for user data, which I see as meaningfully different. 4/
aug 30, 2025, 9:33 pm • 3 0 • view
But if there are other examples, I don’t know them or am not thinking of them. So I’d love any pointers! 5/5
aug 30, 2025, 9:34 pm • 0 0 • view
I think I do, though maybe not always purely content. Move to email?
aug 31, 2025, 9:09 pm • 0 0 • view