Patrons of the Loudoun Library System are just as capable of learning of the existence of any Web site, including blocked sites, as any other user of the Internet since the Loudoun Internet terminals permit full, unfiltered access to all publicly-available Internet search engines. In response to the allegations in paragraphs 131 through 145, Defendant states that those paragraphs contain only legal conclusions which need not be answered, but Defendant denies that the Loudoun County Library Internet Use Policy is unlawful either in its promulgation or in its implementation. To the extent not otherwise answered, all allegations of the Complaint that are not specifically admitted are denied. The Complaint fails to state a claim on which relief may be granted. Defendant is entitled to the absolute immunity provided in 47 U.S.C. 230.
Defendant is entitled to absolute immunity under the doctrine of legislative immunity.
Plaintiffs lack standing to pursue this litigation.