No. 13-5946 Jones v. Dirty World Entm’t Recordings, et al. Page 13 C. This case turns on how narrowly or capaciously the statutory term “development” in § 230(f)(3) is read. The district court held, and Jones maintains on appeal, that Dirty World and Richie are not immune under the CDA because Dirty World and Richie are information content providers with respect to the information underlying Jones’s defamation claims because they developed that information. See Jones IV, 965 F. Supp. 2d at 823. The district court set forth a test to measure whether a defendant is responsible for the development of the information grounding a plaintiff’s state tort claim. According to the district court, “a website owner who intentionally encourages illegal or actionable third-party postings to which he adds his own comments ratifying or adopting the posts becomes a ‘creator’ or ‘developer’ of that content and is not entitled to immunity.” Id. at 821. Dirty World and Richie argue that the district court’s test of development is erroneous, swallowing the protection provided by § 230(c)(1) and undermining the purposes served by the CDA. They maintain that, properly understood, they did not develop the statements forming the basis of Jones’s defamation claims. In our two opinions addressing the CDA, this court has neither expounded the meaning of “development” in § 230(f)(3) nor addressed the scope of immunity that § 230(c) provides. See Seaton, 728 F.3d at 599 n.8; Doe, 551 F.3d at 416. Nevertheless, drawing inferences from these cases, it is not difficult to identify an overly inclusive and exclusive reading of “development.” An overly inclusive interpretation of “development” in § 230(f)(3) would posit that a website operator is responsible for the development of content created by a third party merely by displaying or allowing access to it. Cf. Roommates, 521 F.3d at 1167 (“It’s true that the broadest sense of the term ‘develop’ could include the functions of an ordinary search engine—indeed, just about any function performed by a website.”). But to read the term so broadly would defeat the purposes of the CDA and swallow the core immunity that § 230(c) provides for the “exercise of a publisher’s traditional editorial functions.” See Zeran, 129 F.3d at 330; see also Roommates, 521 F.3d at 1167 (stating that “development” cannot be read to swallow § 230 immunity). Our recognition that the CDA affords immunity forecloses this overbroad reading of “development.”