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University of Illinois Journal of Law, Technology & Policy





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In September 2012, Bettina Wulff, a former first lady of Germany, sued Google for defamation. Mrs. Wulff's complaint arose from Google's autocomplete function: when Mrs. Wulff's name was entered into the search engine, the search engine automatically suggested terms such as "prostitute" and "red light district." Rumors that Mrs. Wulff was a former prostitute dated back to 2006 when she first met Christian Wulff, her eventual husband and president of Germany from 2010 until his resignation in February 2012. Mrs. Wulff denied the truth of these rumors.

Mrs. Wulff contended that these autocomplete results were defamatory and that they caused her great emotional distress. Google maintained that it was not to blame, noting that its autocomplete function merely reflected popular search queries that had been previously entered by other Google users. Some commentators noted that Wulff's lawsuit may backfire, with the lawsuit's publicity prompting more searches of "Bettina Wulff escort," which would "further buoy the term in Google's autocomplete."

This Essay evaluates whether lawsuits like Mrs. Wulff's are feasible in the United States. While § 230 of the Communications Decency Act (CDA) of 1996 poses a significant challenge to defamation lawsuits against websites that display third-party content, recent developments in technology and law create potential avenues around this obstacle. This Essay explores these legal and technological developments and concludes that search engines are not immune from defamation lawsuits arising from autocomplete statements.

Recommended Citation

Michael L. Smith, Search Engine Liability for Autocomplete Defamation: Combating the Power of Suggestion, 2013 U. Ill. J.L. Tech. & Pol'y 313 (2013).



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