created a circuit split on how Section 230 should be considered in those cases. 2020 Department of Justice review In February 2020, the United States Department of Justice held a workshop related to Section 230 as part of an ongoing antitrust probe into "big tech" companies. Attorney General William Barr said that while Section 230 was needed to protect the Internet's growth while most companies were not stable, "No longer are technology companies the underdog upstarts...They have become titans of U.S. industry" and questioned the need for Section 230's broad protections. Barr said that the workshop was not meant to make policy decisions on Section 230, but part of a "holistic review" related to Big Tech since "not all of the concerns raised about online platforms squarely fall within antitrust" and that the Department of Justice would want to see reform and better incentives to improve online content by tech companies within the scope of Section 230 rather than change the law directly. Observers to the sessions stated the focus of the talks only covered Big Tech and small sites that engaged in areas of revenge porn, harassment, and child sexual abuse, but did not consider much of the intermediate uses of the Internet. The DOJ issued their four major recommendations to Congress in June 2020 to modify Section 230. These include: Incentivizing platforms to deal with illicit content, including calling out "Bad Samaritans" that solicit illicit activity and remove their immunity, and carve out exemptions in the areas of child abuse, terrorism, and cyber-stalking, as well as when platforms have been notified by courts of illicit material; Removing protections from civil lawsuits brought by the federal government; Disallowing Section 230 protections in relationship to antitrust actions on the large Internet platforms; and Promoting discourse and transparency by defining existing terms in the statute like "otherwise objectionable" and "good faith" with specific language, and requiring platforms to publicly document when they take moderation actions against content unless that may interfere with law enforcement or risk harm to an individual. Legislation to alter Section 230 In 2020, several bills were introduced through Congress to limit the liability protections that Internet platforms had from Section 230 as a result of events in the preceding years. EARN IT Act of 2020 In March 2020, a bi-partisan bill known as the Eliminating Abusive and Rampant Neglect of Interactive Technologies (EARN IT) Act () was