No. 13-5946 Jones v. Dirty World Entm’t Recordings, et al. Page 19 D. Consistent with our sister circuits, we adopt the material contribution test to determine whether a website operator is “responsible, in whole or in part, for the creation or development of [allegedly tortious] information.” 47 U.S.C. § 230(f)(3). And we expressly decline to adopt the definition of “development” set forth by the district court. The district court read the foregoing decisions, identified Roommates as the guiding precedent, but derived a different rule. In its memorandum opinion explaining the denial of Dirty World’s and Richie’s Rule 50 motion, the district court gave two formulations of a rule providing when the CDA does not bar a plaintiff’s claim. First, the district court said that 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.” Jones IV, 965 F. Supp. 2d at 821. Second, in a different formulation, the district court said that “if . . . [website] owners, as in the instant case, invite invidious postings, elaborate on them with comments of their own, and call upon others to respond in kind, the immunity does not apply.” Id. at 822. The district court arrived at these rules by over-reading the operative language contained in the analytic parts of Johnson, Accusearh, and Chicago Lawyers’ Committee. See id. at 820 (finding that the Johnson “ruling was based on the fact that ‘the record contains no evidence that [the internet service provider] designed its website to be a portal for defamatory material or [did] anything to induce defamatory postings’” (alterations in original) (quoting Johnson, 614 F.3d at 792)); id. (finding that the Accusearch court “held that one is not ‘responsible’ for ‘developing’ allegedly actionable information only ‘if one’s conduct was neutral with respect to the offensiveness of the content’” (quoting Accusearch, 570 F.3d at 1199); id. at 820 (finding that Chicago Lawyers’ Committee “noted that ‘[n]othing in the service craigslist offers induces anyone to post any particular listing or express a preference for discrimination’” (alteration in original) (quoting Chicago Lawyers’ Comm., 519 F.3d at 671−72)). The district court read “inducement” to mean invitation and “neutral with respect to the offensiveness of the content” as a description of a website’s orientation, not of a condition that users upload unlawful content, cf. Roommates,