What are you reading in that decision that suggests Prodigy was doing moderation beyond what we'd expect a typical internet forum to do?
This is the relevant section of your link:
> Plaintiffs further rely upon the following additional evidence
in support of their claim that PRODIGY is a publisher:
> (A)promulgation of "content guidelines" (the "Guidelines" found at
Plaintiffs' Exhibit F) in which, inter alia, users are requested
to refrain from posting notes that are "insulting" and are
advised that "notes that harass other members or are deemed to
be in bad taste or grossly repugnant to community standards, or
are deemed harmful to maintaining a harmonious online community,
will be removed when brought to PRODIGY's attention"; the
Guidelines all expressly state that although "Prodigy is
committed to open debate and discussion on the bulletin boards,
> (B) use of a software screening program which automatically
prescreens all bulletin board postings for offensive language;
> (C) the use of Board Leaders such as Epstien whose duties
include enforcement of the Guidelines, according to Jennifer
Ambrozek, the Manager of Prodigy's bulletin boards and the
person at PRODIGY responsible for supervising the Board Leaders
(see Plaintiffs' Exhibit R, Ambrozek deposition transcript, at
p. 191); and
> (D) testimony by Epstien as to a tool for Board \Leaders known
as an "emergency delete function" pursuant to which a Board
Leader could remove a note and send a previously prepared
message of explanation "ranging from solicitation, bad advice,
insulting, wrong topic, off topic, bad taste, etcetera."
(Epstien deposition Transcript, p. 52).
So they published content guidelines prohibiting harssment, they filtered out offensive languages (presumably slurs, maybe profanity), and the moderation team deleted offending content. This is... bog standard internet forum moderation.
"additional evidence" your quote says. Just before that, we have:
> In one article PRODIGY stated:
> "We make no apology for pursuing a value system that reflects the culture of the millions of American families we aspire to serve. Certainly no responsible newspaper does less when it chooses the type of advertising it publishes, the letters it prints, the degree of nudity and unsupported gossip its editors tolerate."
The judge goes on to note that while Prodigy had since ceased its initial policy of direct editorial review of all content, they did not make an official announcement of this, so were still benefitting from the marketing perception that the content was vetted by Prodigy.
I don't know if I would have ruled the same way in that situation, and honestly, it was the NY Supreme Court, which is not even an appellate jurisdiction in NY, and was settled before any appeals could be heard, so it's not even clear that this would have stood.
A situation where each individual case was decided on its merits until a reasonable de facto standard could evolve I thing would have been more responsible and flexible than a blanked immunity standard which has led to all sorts of unfortunate dynamics that significantly damage the ability to have an online public square for discourse.
[1] https://www.dmlp.org/sites/citmedialaw.org/files/1995-05-24-...