Thanks, the most relevant case for signal appears to be Delfino v. Agilent Technologies where imunity was upheld for an employer whose email system was used by

Thanks, the most relevant case for signal appears to be Delfino v. Agilent Technologies where imunity was upheld for an employer whose email system was used by an employee to send a threatening message. It seems strange for something like this to hinge on section 230 though, were emails providers liable for such things before it was passed ? What about cellular carriers for SMS content ?