No. 13-5946 Jones v. Dirty World Entm’t Recordings, et al. Page 20 521 F.3d at 1166−69, or that contractors conduct unlawful action, cf. Accusearch, 570 F.3d at 1200−01. We do not adopt the district court’s encouragement test of immunity under the CDA. The district court misapprehended how other circuits, particularly the Ninth Circuit in Roommates, have separated what constitutes “development” in § 230(f)(3) from what does not. The district court elided the crucial distinction between, on the one hand, taking actions (traditional to publishers) that are necessary to the display of unwelcome and actionable content and, on the other hand, responsibility for what makes the displayed content illegal or actionable. See Roommates, 521 F.3d at 1169−74. This is the distinction that divides the holdings in Roommates and Accusearch, which stripped the respective defendants of the CDA’s protection, from the holdings in Roommates, Chicago Lawyers’ Committee, Johnson, Batzel, Nemet, and Zeran, which barred the respective plaintiffs’ claims. In Roommates, the website was responsible for the alleged discrimination by requiring users to submit protected characteristics and hiding listings based on those submissions. 521 F.3d at 1165−68. In Accusearch, the website was responsible for the illegal purchase and resale of confidential telephone records. 570 F.3d at 1200−01. But in Chicago Lawyers’ Committee, 519 F.3d at 671−72, and Nemet, 591 F.3d at 256−57, for example, the website operators provided a forum for user posts, did not require users to violate the law as a condition of posting, did not compensate for the posting of actionable speech, did not post actionable content themselves, and therefore were not responsible for the actionable speech that was displayed on their websites. The district court’s rule does not neatly divide these cases. An encouragement theory of “development” does not obviously capture what was allegedly unlawful about the design of Roommate’s website, particularly its search engine, or Accusearch’s payment for unlawful conduct. And it does not obviously leave out the neutral fora created by the commercially oriented websites targeted by the claims in Chicago Lawyers’ Committee and Nemet (craigslist.com and www.consumeraffairs.com, respectively). More importantly, an encouragement test would inflate the meaning of “development” to the point of eclipsing the immunity from publisher-liability that Congress established. Many websites not only allow but also actively invite and encourage users to post particular types of