No. 13-5946 Page 15 Jones v. Dirty World Entm’t Recordings, et al. roommate. Id. The fair housing councils of San Fernando Valley and San Diego sued, alleging that the website violated the Fair Housing Act and state housing discrimination laws. Id. at 1162. The court held that a website operator was not entitled to immunity with respect to allegedly unlawful content that it required its users to submit and with respect to the search engine that was built on that content. Id. at 1165−68. But the court also held that the website was immune as to claims based on the website’s encouragement that users provide additional comments, some of which were alleged to be discriminatory. Id. at 1173−75. To arrive at these divergent holdings, the court applied a specific measure of development: [W]e interpret the term “development” as referring not merely to augmenting the content generally, but to materially contributing to its alleged unlawfulness. In other words, a website helps to develop unlawful content, and thus falls within the exception to section 230, if it contributes materially to the alleged illegality of the conduct. 521 F.3d at 1167−68 (emphasis added). A material contribution to the alleged illegality of the content does not mean merely taking action that is necessary to the display of allegedly illegal content. Rather, it means being responsible for what makes the displayed content allegedly unlawful. Cf. Chicago Lawyers’ Comm., 519 F.3d at 671 (“Causation . . . must refer to causing a particular statement to be made, or perhaps the discriminatory content of a statement. That’s the sense in which a non-publisher can cause a discriminatory ad, while one who causes the forbidden content may not be a publisher.”). “In an abundance of caution,” the Roommates court gave several examples of applications of the “material contribution” test. For example: If an individual uses an ordinary search engine to query for a “white roommate,” the search engine has not contributed to any alleged unlawfulness in the individual’s conduct; providing neutral tools to carry out what may be unlawful or illicit searches does not amount to “development” for purposes of the immunity exception. A dating website that requires users to enter their sex, race, religion and marital status through drop-down menus, and that provides means for users to search along the same lines, retains its CDA immunity insofar as it does not contribute to any alleged illegality. 521 F.3d at 1169. In contrast to this example, the court observed that Roommates required subscribers to disclose information about protected characteristics as a condition of accessing its service and “designed its search and email systems to limit the listings available to subscribers based on sex, sexual orientation and presence of children.” Id. at 1166, 1169. Because