Netchoice, LLC v. Fitch

CourtDistrict Court, S.D. Mississippi
DecidedJune 18, 2025
Docket1:24-cv-00170
StatusUnknown

This text of Netchoice, LLC v. Fitch (Netchoice, LLC v. Fitch) is published on Counsel Stack Legal Research, covering District Court, S.D. Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Netchoice, LLC v. Fitch, (S.D. Miss. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI SOUTHERN DIVISION

NETCHOICE, LLC § PLAINTIFF § § v. § Civil No. 1:24-cv-170-HSO-BWR § § LYNN FITCH, § in her official capacity as § Attorney General of Mississippi § DEFENDANT

MEMORANDUM OPINION AND ORDER GRANTING IN PART AND DENYING IN PART PLAINTIFF NETCHOICE, LLC’S MOTION [49] FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION

Plaintiff NetChoice, LLC seeks to enjoin Sections 1 through 8 of Mississippi House Bill 1126 (“H.B. 1126” or the “Act”), which was signed into law on April 30, 2024, and originally set to take effect on July 1, 2024. See Mot. [49]. NetChoice asks this Court to preliminarily enjoin Defendant Lynn Fitch, in her official capacity as Mississippi Attorney General, from taking any action to enforce the challenged portions of H.B. 1126. See id.; Mem. [50]. The Attorney General opposes the Motion [49]. See Resp. [54]. After consideration of the record and relevant legal authority, including the Fifth Circuit’s prior opinion in this case and the United States Supreme Court’s decision in Moody v. NetChoice, LLC, 603 U.S. 707 (2024), and because the Court finds the Act unconstitutional as applied to certain of Plaintiff NetChoice, LLC’s members, a preliminary injunction should issue pending final disposition of this case on the merits. Mississippi Attorney General Lynn Fitch and her agents, employees, and all persons acting under her direction or control, will be preliminarily enjoined from enforcing Sections 1-8 of Mississippi House Bill 1126

against Plaintiff NetChoice, LLC’s eight covered members: (1) Dreamwidth; (2) Meta, which owns and operates Facebook and Instagram; (3) Nextdoor; (4) Pinterest; (5) Reddit; (6) Snap Inc., which owns and operates Snapchat; (7) X; and (8) YouTube. I. BACKGROUND A. NetChoice Plaintiff NetChoice, LLC (“NetChoice” or “Plaintiff”) is a nonprofit trade

association for internet companies. Am. Compl. [48] at 5. Its Amended Complaint [48] asserts that H.B. 1126 regulates some services offered by the following of its members: (1) Dreamwidth; (2) Meta, which owns and operates Facebook and Instagram; (3) Nextdoor; (4) Pinterest; (5) Reddit; (6) Snap Inc., which owns and operates Snapchat; (7) X; and (8) YouTube. Id. According to NetChoice’s General Counsel and Director of Strategic Initiatives Bartlett Cleland

(“Cleland”), its members’ websites “publish, disseminate, display, compile, create, curate, and distribute a wide range of valuable and protected expression to their users,” and “disseminate content (text, audio, graphics, and video) that facilitates their users’ ability to practice their religious beliefs, engage in political discourse, seek cross-cultural dialogue, supplement their education, learn new skills, and simply interact socially.” Ex. [49-1] at 3. Cleland’s Declaration states that the Act covers at least eight of NetChoice’s members which are known as “social media” websites whose “interactive functionality is the point of the service.” Id. at 23. Each allows its account

holders to upload and publicly post content, which other account holders may then view and react to, comment on, or share with others. Id. at 22. According to Cleland, users of these social media websites “engage in protected speech activities, including speaking to others and viewing content created by others.” Id. He opines that the Act’s burdensome requirements “will make it more difficult for NetChoice members to provide their websites to minors and adults, and will burden minors and adults’ access to highly valuable and protected speech.” Id. at 24.

B. Mississippi H.B. 1126 Sections 1-8 of H.B. 1126 provide in relevant part as follows: SECTION 3. (1) This act applies only to a digital service provider who provides a digital service that: (a) Connects users in a manner that allows users to socially interact with other users on the digital service; (b) Allows a user to create a public, semi-public or private profile for purposes of signing into and using the digital service; and (c) Allows a user to create or post content that can be viewed by other users of the digital service, including sharing content on: (i) A message board; (ii) A chat room; or (iii) A landing page, video channel or main feed that presents to a user content created and posted by other users.

Ex. [1-1] at 3-4 (Miss. H.B. 1126, § 3(1)). The Act does not apply to a digital service provider that “processes or maintains user data in connection with the employment, promotion, reassignment or retention of the user as an employee or independent contractor, to the extent that the user’s data is processed or maintained for that purpose.” Id. at 4 (Miss. H.B. 1126, § 3(2)(a)). Nor does the Act apply to a provider’s service that “facilitates e- mail or direct messaging services, if the digital service facilitates only those

services,” primarily functions to provide a user with access to certain career development opportunities, or primarily functions “to provide a user with access to news, sports, commerce, online video games or content primarily generated or selected by the digital service provider” and “[a]llows chat, comment or other interactive functionality that is incidental to the digital service.” Id. at 4-5 (Miss. H.B. 1126, § 3(2)(b)-(c)). Under Section 4,

(1) A digital service provider may not enter into an agreement with a person to create an account with a digital service unless the person has registered the person’s age with the digital service provider. A digital service provider shall make commercially reasonable efforts to verify the age of the person creating an account . . . . (2) A digital service provider shall not permit an account holder who is a known minor to be an account holder unless the known minor has the express consent from a parent or guardian . . . .

Id. at 5-7 (Miss. H.B. 1126, § 4).

Section 6 states that for a “known minor’s use of a digital service, a digital service provider shall make commercially reasonable efforts to develop and implement a strategy to prevent or mitigate the known minor’s exposure to harmful material and other content that promotes or facilitates” certain specified harms. Id. at 8 (Miss. H.B. 1126, § 6(1)). These harms are identified in subsection (1) and include self-harm, eating disorders, substance use disorders, suicidal behaviors, stalking, grooming, incitement of violence, and any other illegal activities. Id. But [n]othing in subsection (1) shall be construed to require a digital service provider to prevent or preclude: (a) Any minor from deliberately and independently searching for, or specifically requesting, content . . . .

Id. at 8-9 (Miss. H.B. 1126, § 6(2)(a)). In sum, Section 4(1) of H.B. 1126 requires all users, adults and minors alike, to verify their age before they may open an account with a covered digital service provider (the “age-verification requirement”), while Section 4(2) requires consent from a parent before a known minor may create an account (the “parental-consent requirement”). Id. Section 5 imposes a limitation on the collection of data by covered digital service providers that enter into an agreement with a known minor for access to a digital service (the “data-collection limitation”), and Section 6 requires those digital service providers to make commercially reasonable efforts to develop and implement a strategy to prevent or mitigate the known minor’s exposure to harmful material and other content that promotes or facilitates certain harms to minors (the “prevention-or-mitigation requirement”).1 See id. But Section 6(2) does not require digital service providers to prevent or preclude minors with accounts from “deliberately and independently searching for, or specifically requesting, content.” Id.

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Netchoice, LLC v. Fitch, Counsel Stack Legal Research, https://law.counselstack.com/opinion/netchoice-llc-v-fitch-mssd-2025.