In 2020 Judge Clarence Thomas made a statement in respect of denying certiorari to Malwarebytes, Inc. v. Enigma Software Group USA, LLC., which referenced Robert Katzman's dissent in Force v. Facebook. He opined that section 230 had been interpreted too broadly, and could be narrowed or eliminated in a future case, which he urged his colleagues to hear. Consequently in 2023 the Supreme Court agreed to hear two cases considering whether Social media can be held liable for "aiding and abetting" in acts of international terrorism, when their recommender systems promote it. Numerous experts have suggested that changing 230 without repealing it entirely would be the optimal way to improve it. Google's former fraud czar Shuman Ghosemajumder proposed in 2021 that full protections should only apply to unmonetized content, to align platforms' content moderation efforts with their financial incentives, and to encourage the use of better technology to achieve that necessary scale. Researchers Marshall Van Alstyne and Michael D. Smith supported this idea of an additional duty-of-care requirement. However, journalist Martin Baron has argued that most of Section 230 is essential for social media companies to exist at all. Platform neutrality Some politicians, including Republican senators Ted Cruz (TX) and Josh Hawley (MO), have accused major social networks of displaying a bias against conservative perspectives when moderating content (such as Twitter suspensions). In a Fox News op-ed, Cruz argued that section 230 should only apply to providers that are politically "neutral", suggesting that a provider "should be considered to be a liable 'publisher or speaker' of user content if they pick and choose what gets published or spoke." Section 230 does not contain any requirements that moderation decisions be neutral. Hawley alleged that section 230 immunity was a "sweetheart deal between big tech and big government". In December 2018, Republican representative Louie Gohmert introduced the Biased Algorithm Deterrence Act (H.R.492), which would remove all section 230 protections for any provider that used filters or any other type of algorithms to display user content when otherwise not directed by a user. In June 2019, Hawley introduced the Ending Support for Internet Censorship Act (S. 1914), that would remove section 230 protections from companies whose services have more than 30 million active monthly users in the U.S. and more than 300 million worldwide, or have over $500 million in annual global revenue, unless they receive a certification from the majority of the