No. 13-5946 Jones v. Dirty World Entm’t Recordings, et al. Page 22 theory of “development” would undermine the CDA for the same reasons as an encouragement theory. See Parisi v. Sinclair, 774 F. Supp. 2d 310, 316 (D.D.C. 2011) (dismissing plaintiffs’ claims as barred by the CDA despite their argument that defendant “adopted” the statements at issue as its own and finding that “it would be contrary to the purpose of the CDA, which sought to encourage the vibrant and competitive free market of ideas on the Internet, by establishing immunity for internet publication of third-party content to require a fact-based analysis of if and when a defendant adopted particular statements and revoke immunity on that basis” (internal citations and quotation marks omitted)). III. We now apply the material contribution measure of “development” to the facts of this case. Jones’s defamation claims target the statements that were posted by a third party on October 27 and December 7, 2009. Because Dirty World and Richie did not materially contribute to the illegality of those statements, the CDA bars Jones’s claims. See Nemet, 591 F.3d at 260 (affirming dismissal where plaintiff failed to show defendant “was responsible for the creation or development of the allegedly defamatory content at issue” (emphasis added)). Dirty World and Richie did not author the statements at issue; however, they did select the statements for publication. But Richie and Dirty World cannot be found to have materially contributed to the defamatory content of the statements posted on October 27 and December 7, 2009, simply because those posts were selected for publication. See Batzel, 333 F.3d at 1035 (holding that an editor of an email newsletter who received and published allegedly actionable information, adding a short headnote, was immune under § 230 because an editor’s changes to the length and spelling of third-party content do not contribute to the libelousness of the message). Nor can they be found to have materially contributed to the defamatory content through the decision not to remove the posts. See Zeran, 129 F.3d at 330 (holding CDA immunity applied even though “AOL unreasonably delayed in removing defamatory messages posted by an unidentified third party, refused to post retractions of those messages, and failed to screen for similar postings thereafter”). The CDA expressly bars “lawsuits seeking to hold a service provider liable for its exercise of a publisher’s traditional editorial functions—such as deciding whether to publish, withdraw, postpone or alter content.” Id.