On August 27, 2025, the imageboard website 4chan Community Support LLC (“4chan”) and discussion forum Lolcow, LLC (dba “Kiwi Farms”) (together, the “Plaintiffs”)  filed a claim in the U.S. District Court of the District of Columbia (“Court”) asking the Court to declare, in effect, that the UK’s Online Safety Act 2023 (“OSA”) is unenforceable against the Plaintiffs. The claim was filed against Ofcom, the UK’s communications services regulator tasked with regulating and enforcing the OSA.

The Plaintiffs allege that the enforcement of the OSA against American companies is unconstitutional and that Ofcom’s actions to enforce the OSA are “intended to deliberately undermine the First Amendment and American competitiveness” (para. 113). As part of their claim, the Plaintiffs seek two permanent injunctions: one prohibiting Ofcom from enforcing the OSA against the Plaintiffs, and the other prohibiting Ofcom from issuing any further orders or demands to the Plaintiffs without “proper service” under the U.S.-UK Mutual Legal Assistance Treaty.

Background

The OSA imposes various obligations on “user-to-user” (“U2U”) services—i.e., services through which users “generate” and “encounter” content created by other users, e.g., social media and file-sharing service— to address the presence and prevalence of “illegal content”—such as terrorist content, revenge pornography, and child sexual exploitation material—on their services. U2U services that are “likely to be accessed by children” are also required to take steps to address content that is legal, but “harmful to” children. These obligations have come into force throughout 2025. Failure to comply with provisions of the OSA may result in penalties of GBP 18 million or 10% of worldwide revenue, whichever is greater.

Ofcom opened an investigation into 4chan’s compliance with the OSA in June 2025, following 4chan’s failure to adequately respond to various statutory information requests, including a request to disclose its illegal content risks assessments. Ofcom also sent formal communications to Kiwi Farms in March and July 2025 requesting records of their risk assessments. The Plaintiffs argue that such communications were not validly served under the U.S.-UK Mutual Legal Assistance Treaty.

Jurisdiction

The Plaintiffs argue that the Court has “subject matter jurisdiction over this action … because [it] arises under the Constitution and laws of the United States, specifically the First, Fourth, and Fifth Amendments to the Constitution and the Communications Decency Act” (para. 14), and that it has “personal jurisdiction” over Ofcom pursuant to the District of Columbia’s “long-arm statute, as Ofcom has committed unlawful acts within the District of Columbia by sending threatening communications to U.S.-based internet companies that interfere with their constitutional rights and business operations” (para. 15). It remains to be seen whether these jurisdictional arguments will be accepted by the Court.

* * *

The Covington team continues to closely monitor developments in online safety, including the implementation of the OSA.  Please reach out to a member of the team if you have any questions.

Photo of Shona O'Donovan Shona O'Donovan

Shóna O’Donovan is an associate in the technology regulatory group in the London office. She advises clients, particularly in the technology industry, on a range of data protection, e-privacy, intermediary liability and online content issues under EU, UK, and Irish law.

Shóna provides…

Shóna O’Donovan is an associate in the technology regulatory group in the London office. She advises clients, particularly in the technology industry, on a range of data protection, e-privacy, intermediary liability and online content issues under EU, UK, and Irish law.

Shóna provides strategic advice to companies on complying with data protection, e-privacy and online content laws, as well as defending organizations in cross-border, contentious investigations and regulatory enforcement before EU and UK regulators. In this context, she has represented clients in responding to regulatory requests relating to their compliance with the GDPR, the ePrivacy Directive, the Digital Services Act, the Audiovisual Media Services Directive and the Online Safety Act 2023. She also regularly advises clients on how these laws intersect with one another.

In her current role, Shóna gained experience on secondment to the data protection team of a global technology company. In a previous role, she spent seven months on secondment to the European data protection team of a global social media company.

Shóna co-leads Covington’s pro bono work with the Schools Consent Project, and regularly delivers workshops on sexual consent in schools across London. She also regularly provides pro bono advice to non-profits on complying with data protection laws.

Photo of Stacy Young Stacy Young

Stacy Young is an associate in the London office. She advises technology and life sciences companies across a range of privacy and regulatory issues spanning AI, clinical trials, data protection and cybersecurity.

Photo of Dumitha Gunawardene Dumitha Gunawardene

Dumitha Gunawardene is an associate in the Commercial Litigation Practice Group. His practice covers a broad range of complex commercial and contractual disputes and international commercial arbitrations. Dumitha has represented clients in the English High Court as well as in arbitrations under ICC…

Dumitha Gunawardene is an associate in the Commercial Litigation Practice Group. His practice covers a broad range of complex commercial and contractual disputes and international commercial arbitrations. Dumitha has represented clients in the English High Court as well as in arbitrations under ICC, LCIA and DIAC Rules.