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Freedom of Speech in Online Game Worlds

In the offline world, we've seen thisdeliver email messages when a spammer tried
intersection in (among other situations) U.S.to send spam through AOL's network. In other
Supreme Court cases addressing private speechwords, in theory, courts could do something
at privately owned company towns and shoppingabout providers squelching speech, but have
centers. In some cases, the Supreme Court hassided with providers because the Constitution
said that certain landowners cannot preventdoesn't apply in these cases. But how do we
speakers from speaking on their privatedistinguish between AOL's response to spam
property. However, in other cases, the(which seems right) and a virtual world's
landowner's property rights have trumped thedecision to kick off a user? In both cases,
speaker's right to speak on the property,the online provider can choose, but we're
allowing the landowner to "censor" thetempted to side with AOL on spam and side
speaker.In the online world, the speechagainst virtual world providers on everything
rights dichotomy raises equally complexelse. It's that inconsistency that I'm trying
issues. Online private actors routinely useto address here.The virtual world industry is
their private property (such as computers andburgeoning. Millions of users participate in
networks) to create virtual spaces designedsuch complex interactive spaces as EverQuest,
for speech, although speaker access isSecond Life, World of Warcraft, and The Sims
usually controlled by contract. An onlineOnline. With the emergence of these "virtual
provider exercising its property or contractworlds," we must once again consider how we
rights inevitably squelches a speaker'sbalance a customer's speech against a virtual
rights. But despite online providers'world provider's rights to squelch speech. To
capacity to exercise their rightsstrike a balance, we must decide whether
capriciously, courts so far have unanimouslyvirtual worlds are more like physical world
held that private online providers are notcompany towns or shopping centers, or are
state actors for First Amendment purposes. Injust another category of online providers.
one representative case, AOL could refuse to



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