But I don't think safe harbour was entirely new with DMCA - it's a formalisation of what was there? Wasn't there some cases in the 90s where free web hosts and

But I don't think safe harbour was entirely new with DMCA - it's a formalisation of what was there? Wasn't there some cases in the 90s where free web hosts and isps were found to not be responsible for users hosting copyright material? Maybe I misremeber.