changes to Section 230 to make Internet companies liable for not being proactive in taking down hate speech. O'Rourke later dropped out of the race. Fellow candidate and former vice president Joe Biden has similarly called for Section 230 protections to be weakened or otherwise "revoked" for "big tech" companies—particularly Facebook—having stated in a January 2020 interview with The New York Times that "[Facebook] is not merely an internet company. It is propagating falsehoods they know to be false", and that the U.S. needed to "[set] standards" in the same way that the European Union's General Data Protection Regulation (GDPR) set standards for online privacy. Immunity from content related to illegal activities In the aftermath of the Backpage trial and subsequent passage of FOSTA-SESTA, others have found that Section 230 appears to protect tech companies from content that is otherwise illegal under United States law. Professor Danielle Citron and journalist Benjamin Wittes found that as late as 2018, several groups deemed as terrorist organizations by the United States had been able to maintain social media accounts on services run by American companies, despite federal laws that make providing material support to terrorist groups subject to civil and criminal charges. However, case law from the Second Circuit has ruled that under Section 230, technology companies are generally not liable for civil claims based on terrorism-related content. U.S. Supreme Court Justice Clarence Thomas has stated that Section 230 gives companies too much immunity in these area, as reported in his several dissenting statements to court orders denying certification of cases related to Section 230. Thomas believed that the Supreme Court needed to review the limits granted by Section 230. The Supreme Court will hear the cases of Gonzalez v. Google LLC and Twitter, Inc. v. Taamneh in the 2022 term. Gonzalez involves Google's liability for the YouTube recommendation options that appeared to promote recruitment videos for ISIS that led to the death of a U.S. citizen in a 2015 Paris terrorist attack. Google has claimed it is not liable under Section 230 protections. In Twitter, the company had been found liable for hosting terrorism-related content from third-party users under the Anti-Terrorism Act under 18 U.S.C. § 2333, without the consideration of Section 230's protections. Starting in January 2023, the Supreme Court will also consider petitions related to rulings related to the Texas and Florida online speech laws, as lower Appeals Courts have