In order to better understand patterns related to human trafficking online, this section offers a review of a set of U.S. federal cases involving human trafficking via online channels, beginning with an overview of some of the applicable domestic laws related to trafficking. The following is only a sampling of U.S laws relevant to this complex issue.

Relevant Trafficking Laws

At the federal level, numerous domestic laws might be applied to human trafficking cases. Sex trafficking was criminalized by 18 U.S.C. §1591, which makes it illegal to recruit, entice, provide, harbor, maintain, or transport a person or to benefit from involvement in causing the person to engage in a commercial sex act, knowing that force, fraud, or coercion was used or that the person was under the age of 18. Sex traffickers also may face charges under other federal statutes applicable to sex trafficking, such as 18 U.S.C. § 2423(a), prohibiting transportation of a minor with intent that the individual engage in criminal sexual activity. On the labor trafficking side, 18 U.S.C. §§1589-1590 make it illegal to knowingly provide or obtain the labor of a person by certain means, such as force or threats of force, or to traffic a person for labor or services by means of force, coercion, or fraud for the purpose of subjecting the person to slavery, involuntary servitude, debt bondage, or peonage.

Federal laws addressing human trafficking apply across the country; state laws addressing trafficking also exist, but vary in terms of definitions, penalties, and enforcement priorities. While most states have recognized and criminalized sex trafficking,1 many have only recently done so, and with significant variations in penalties imposed on perpetrators. According to the State Department’s 2011 TIP Report, “While state prosecutions continue to increase, one study found that less than 10% of state and local law enforcement agencies surveyed had protocols or policies on human trafficking.”2

The above laws address the criminalization of a trafficker’s conduct, but a trafficked victim can potentially face criminal charges, depending on whether the applicable law offers the victim protection. For example, under federal law, a 16-year-old engaged in commercial sex acts is a trafficking victim, regardless of whether the minor appears to have participated willingly in said acts, because the law presumes that an underage victim cannot provide legal consent. However, the protections available to trafficking victims vary between states, and minor victims of sex trafficking can face prostitution charges in some state courts.3

In April 2010, New York became the first state to pass legislation addressing this issue, with the Safe Harbor for Exploited Children Act.4 The act prohibits the prosecution of minors for prostitution. Several states would subsequently pass similar legislation.5

Evidence From Federal Cases

Fiscal year 2010 saw the greatest number of U.S. federal human trafficking prosecutions initiated in a single year. According to the 2011 TIP Report, “Collectively federal law enforcement charged 181 individuals, and obtained 141 convictions in 103 human trafficking prosecutions (32 labor trafficking and 71 sex trafficking).”6 The average prison sentence was 11.8 years, with prison terms ranging from 3 months to 54 years.7 The Internet and online tools played roles in a number of these cases.

A scan of recent legal cases involving human trafficking and online technologies provides insights regarding details about the uses of technology by traffickers.8 The primary sources for details of trafficking investigations were press releases from the Federal Bureau of Investigation, the U.S. Department of Justice, and U.S. Immigrations and Customs Enforcement. A search of press releases from these organizations using a combination of terms including “sex trafficking,” “forced labor,” “labor trafficking,” “human trafficking,” “minor,” “prostitution,” “online,” “advertisement,” and “Internet” produced a set of cases that were manually reviewed for relevance, with results limited to cases involving either a guilty plea or a conviction. The search did not produce any cases involving labor trafficking and online technologies; all of the results reviewed were related to sex trafficking. The following is based on a self-selected sample of 27 federal trafficking cases since 2009 involving the use of social networking sites or online classified advertisements to facilitate trafficking. A search of legal databases, using keywords including “sex trafficking,” “labor trafficking,” “human trafficking,” “minor,” “website,” “online,” and “Internet”—as well as searches for convictions under 18 U.S.C. §§ 1590-15919—produced examples illustrating the use of the Internet to facilitate trafficking.

The cases collected do not indicate the totality of trafficking cases involving social networking sites and online classifieds but rather serve to demonstrate some of the ways in which technology is used to facilitate trafficking and the patterns that begin to emerge across cases.

Labor Trafficking and Technology

In the course of this study, researchers did not discover evidence of traffickers utilizing the Internet to facilitate labor trafficking, perhaps due to the circumstances typically surrounding this form of trafficking. Research suggests that victims often are recruited from impoverished regions and typically learn about opportunities via word of mouth. Once recruited, workers may be isolated, without access to technology. “Most of the victims we’re seeing are from underdeveloped countries,” said Anna Park, regional attorney for the Equal Employment Opportunity Commission (EEOC), Los Angeles District Office. “In the cases we’ve had,” she noted, the use of technology “is very unlikely.”10

Employment discrimination laws have become instrumental in the fight against labor trafficking.11 Park was involved in a case brought by the Los Angeles District Office of the EEOC against Trans Bay Steel,12 in which the EEOC filed a class national-origin discrimination action on behalf of a group of Thai welders who were trafficked and forced into labor. Initially recruited by an agency to work as high-skilled welders and provided with legitimate visas, the workers were subsequently “held against their will, had their passports confiscated, had their movements restricted, and were forced to work without pay all in violation of Title VII. Additionally, some workers were confined to cramped apartments without any electricity, water, or gas.”13

What we have seen are temporary contracting agencies bringing in workers through legitimate means under the auspices of luring people with the promise of work so that they can lead a better life. However, the victims are charged exorbitant fees that the workers can never pay because, oftentimes, they are never paid for their work. This fee is used to subjugate and exploit the workers, forcing them to tolerate and endure intolerable situations.14

According to Park, most of the targeted communities are agrarian, and people typically learn about job opportunities from neighbors and members of their communities. Newspapers in languages targeting a monolithic group (e.g., Thai newspapers) also may advertise positions that turn out to be labor trafficking, particularly in light of the fact that many of the employment agencies involved in trafficking are otherwise legitimate and likely advertise. In the event that these community newspapers move online, there may be an opportunity to evaluate how online classifieds may be used for labor trafficking.

The U.S. Attorney’s Office in Atlanta offered a similar assessment of technology in the context of labor trafficking, noting that labor traffickers do not use much technology and that such uses tend to be limited to pay-as-you-go cellphones.15 However, as rural communities gain access to the Internet, there will be a need to study the benefits of online technologies as well as their potential use as tools of manipulation, depicting a false reality designed to lure persons away from their homes and into forced labor.16

The lack of examples of online communication with respect to labor trafficking might also stem from the nature of the messages communicated by traffickers—namely employment opportunities and promises of fair wages. Unlike sex traffickers, who advertise using language that signals the nature of the available services (e.g., using terms such as “young”), labor traffickers rely on deceit, making compelling false promises. The challenge is to decipher which job advertisements will result in labor trafficking once the laborer responds to the advertisement and arrives for work. Unless the recruiters, employers, or other details of their advertisements have already been identified for trafficking abuses, it is immensely difficult to design studies wherein observing online communications alone will reveal disingenuous intentions. The unique features of the labor trafficking system make it particularly challenging to track through Internet tools and technologies at this time.

Sex Trafficking and Technology

Although easier to track than labor trafficking, determining instances of sex trafficking online poses its own complications. In particular, distinctions between advertisements of trafficking victims as opposed to sex workers who do not fall within the legal definitions of trafficking can be limited and blurred. Focusing on some of the most vulnerable victims of trafficking, this report directs its research and technological solutions toward detecting minors advertised for commercial sexual services. Under the TVPA, all minors engaged in commercial sex acts are treated as victims of trafficking.17 Although advertisements frequently misrepresent the age of victims, certain keywords meant to serve as signals for the purchasers who drive the demand for sex with minors make detection a possibility. Although the signals and terms change frequently, the nature of advertising a minor’s sexual services to purchasers with particular age and characteristic preferences makes it possible to detect common themes across online classified ads.

Focusing on the set of cases in which the Internet is used by sex traffickers, certain patterns begin to emerge: (1) Online classified sites are used to post advertisements of victims, (2) social networking sites are used in the recruitment of victims, (3) investigations may begin with a picture of what appears to be an underage girl in an online classified ad, and (4) a number of victims have been identified as runaways.

The Internet was used to advertise the sexual services of victims in all of the cases reviewed. For example, Byron Thompson, who pled guilty to sex trafficking in Maryland in July 2009, created Craigslist and Backpage postings advertising the sexual services of his victims, who were featured in photographs in the ads.18 In January 2011, Clint Wilson pled guilty to sex trafficking in a Texas federal court. Wilson posted ads on Backpage, offering commercial sex services by his minor victim, who was featured in the ads.19 A Florida federal jury found Tyrone Townsend guilty of sex trafficking in February 2011. Among the evidence collected by investigators were 28 Internet ads and a Garmin GPS seized from Townsend’s vehicle. Using the GPS, investigators were able to establish locations of several customers in the Jacksonville area.20

In a case filed in the Southern District of New York, United States v. Daniel Marino, et al., 14 members and associates of the Gambino organized crime family pled guilty to various federal charges, including sex trafficking and sex trafficking of a minor.21 Several of the defendants operated a prostitution business, through which they exploited young women and girls for commercial sex. The business was advertised on Craigslist and other websites.22

While Craigslist was the most frequently referenced website in the cases reviewed, the “Adult Services” section of the site has since closed. “The source now is Backpage,” noted the U.S. Attorney’s Office in Atlanta, “aside from underground and quasi-underground chat rooms.”23

Describing the challenges of reviewing online classified ads in search of trafficking activity, the office added: “It’s not easy to quantify or to identify someone who is using code words. You would have to weed through, in theory, a hundred ads before you get the one.”24 The task of manually sorting through myriad advertisements is a strain on often-limited law-enforcement resources. Without some technological solutions to narrow the pool of potential advertisements, the task of manually reviewing these ads exceeds the limits of what investigators can reasonably expect to achieve.

Beyond advertising sexual services, traffickers also use the Internet to interact with potential victims. In four of the cases reviewed, traffickers used social media as a recruiting tool. In June 2010, Dwayne Lawson was sentenced to 210 months in federal prison after pleading guilty to sex trafficking of children. The investigation began when Los Angeles police arrested a teenage girl for prostitution. Investigators learned that the girl was a runaway working for Lawson, who initially “contacted the girl in the fall of 2008 on and, after promising to make her a ‘star,’ gave her a bus ticket from Florida to Las Vegas, Nevada.”25

A common starting point for investigators is the appearance of the victim in photos used by sex traffickers to advertise. According to public records, the U.S. Attorney’s Office in Atlanta said, agents frequently review pictures in online classified ads, noting when a girl seems younger than her advertised age. Agents may then undertake investigations based on a picture that appears to feature an underage girl.

In August 2010, Lawrence Pruitt and Marvin Harris were sentenced to 10 years and four years, respectively, in federal prison for sex trafficking of a minor. Agents investigating the possible prostitution of underage girls arrested the pair at an Atlanta-area hotel, where investigators found the victim, a 17-year-old “whose photographs the agents had previously seen on an Internet website advertising erotic services. The FBI believed that the victim, whose advertisement listed her age as 19, was a juvenile.”26

The investigation of Thelonious Reed, sentenced in June 2009 on charges related to sex trafficking, began when an agent discovered an ad for a young woman in the Erotic Services section of Craigslist. The ad, in which a young woman appeared topless, described the woman as 19 years old. Believing her to be younger, the agent set up a meeting posing as a client. Upon arrival, the 18-year-old victim revealed that she was trafficked for sex by Reed, who lured her by describing himself as a modeling agent.27

However, investigating based upon a photo is not without complications, as in some cases a fake or doctored image may be used to advertise the victim’s services. “That makes it even harder to peel back the layers and get to the trafficked female,” noted the U.S. Attorney’s Office in Atlanta.28

In several of the cases reviewed, investigators discovered the victims were runaways.29 This finding corresponds to the 2011 U.S. Trafficking in Persons Report, “U.S. citizen child victims [of sex trafficking] are often runaways, troubled, and homeless youth.”30 In May 2010, Ezekiel Alon Hampton of Tacoma, Washington, was sentenced to 13 years in prison for counts involving sex trafficking. The investigation began when the police department contacted a young runaway about a reported assault and discovered that the 14-year-old girl was being trafficked, along with several other young women. The girl, who had recently left Hampton, explained that he made the girls advertise their sexual services on Craigslist. All of the victims turned out to be runaways, and Hampton provided them with housing, food, and drugs.31

In October 2010, Sterling Terrance Hospedales, a former Army sergeant, was sentenced to 11 years for sex trafficking and attempted sex trafficking of a child. The investigation began in Lakewood, Washington, when local police received reports of a young runaway posting ads selling sexual services on Craigslist. Investigators located and interviewed the juvenile, who led them to Hospedales. Investigators also discovered another juvenile victimized by Hospedales. The second juvenile had met him on Myspace. Hospedales paid for her plane ticket and, within a week, posted photos of her on Craigslist advertising sexual services. In a memo, prosecutors emphasized that Hospedales had targeted susceptible juveniles, “Hospedales intentionally sought out emotionally damaged, vulnerable victims—runaways who had no support system whatsoever and no idea of how to be in a normal, functioning relationship.”32

The Human Trafficking Rescue Project conducted a sting operation in March 2009 targeting individuals attempting to engage in sex with prostituted children.33 Ads were posted on Craigslist describing children available for sex; however, no children were actually involved in the operation. Richard Oflyng, a Kansas truck driver who responded to an ad describing “little girls,” was arrested after making an appointment to have sex with an 11-year-old girl. Oflyng pled guilty and was sentenced to 15 years in federal prison for attempted sex trafficking.34

“This sentence serves as a warning,” said Gilbert Trill, assistant special agent, ICE Office of Investigations, Kansas City. “Some child predators mistakenly believe the anonymity of cyberspace shields them from scrutiny. In fact, their use of the Internet gives us new tools in our efforts to investigate this insidious behavior.”35

At the prosecution stage, a broad reading of the interstate commerce element of §1591(a)(1)36 allows prosecutors to bring a potentially wider range of sex trafficking cases involving online activity under federal trafficking laws, as illustrated in the recent Eleventh Circuit decision in United States v. Timothy Myers. The defendants, who were charged with trafficking two girls under the age of 18 for sex, placed advertisements featuring their victims on Craigslist and Backpage. Testimony from Craigslist’s customer service manager revealed that “the data for its websites was stored on servers in Arizona and California and that Craigslist payments end up in the company accounts in California, where the company is based.”37

The court concluded that the interstate commerce element of the statute was satisfied, by virtue of the movement of monies through accounts and information through servers in various states.38 With many social networking and online classified sites maintaining servers in multiple states, decisions such as United States v. Myers could allow a greater number of prosecutors to bring sex trafficking cases involving online activity in federal courts, allowing victims to benefit from the protections offered under the TVPA.

Case Study: Craigslist Under Fire

Due in part to increasing reports citing Craigslist’s role in trafficking and sexual exploitation, in September 2010, the website shut down its Adult Services section in all U.S. cities. By December, the company closed the Adult Services sections of the website worldwide.

Since 2007, Craigslist has been criticized for its role in facilitating prostitution and sexual exploitation via its Adult Services (formerly Erotic Services) sections.39 In November 2008, Craigslist began charging users of its U.S. sites a $5 credit card fee for adult ads, requiring a phone number to verify the identity of the user and to help police better track the postings to the actual users.40 In May 2009, the company renamed its Erotic Services section Adult Services.41 The change in policy included a fee increase to $10 and the hiring of attorneys to manually filter ads.42 Craigslist reported that it would continue cooperating with law enforcement to crack down on ads selling sex.43

But a number of politicians, advocates, and law-enforcement officials were not persuaded. “I believe Craigslist acted irresponsibly when it unilaterally decided to keep the profits from [sex ad] posts,” said Connecticut Attorney General Richard Blumenthal.44 Yet when Craigslist attempted to donate monies to a nonprofit group, the Advocates for Human Rights, the unsolicited contribution was rejected.45 Along with 17 other state attorneys general, Blumenthal in 2010 sent a letter to Craigslist demanding the removal of the Adult Services section.46

In March 2009, Illinois Cook County Sheriff Thomas Dart, filed a suit in the Northern District of Illinois against Craigslist, alleging, “Missing children, runaways, abused women and women trafficked in from foreign countries are routinely forced to have sex with strangers because they’re being pimped on Craigslist.”47 Craigslist asserted that §230(c)(1) of the Communications Decency Act of 1996 protected it from liability for the distribution of third-party content. The court agreed that §230(c)(1) applied and granted Craigslist’s motion for judgment on the pleadings.48

As the campaign against Craigslist continued to gain momentum, a research study commissioned by the Women’s Funding Network, conducted by the Schapiro Group, reported numbers related to the trafficking of minors via online classified ads. The report was cited in congressional hearings, despite the fact that aspects of the methodology were not rigorous.

On September 15, 2010, the House Subcommittee on Crime, Terrorism, and Homeland Security conducted a hearing on domestic minor sex trafficking and specifically H.R. 5575, the Domestic Minor Sex Trafficking Deterrence and Victims Support Act of 2010.49 The subcommittee expressed particular concern that advertisements for sex trafficking appeared online on Internet sites such as Craigslist.50

U.S. Representative Jackie Speier (D-CA) stated, “The activity taking place on, and Backpage is equally as horrific…These sites are facilitating crimes.”51

During the hearing, William Powell, director of customer service and law enforcement relations for Craigslist, highlighted the company’s steps to address concerns that a subset of ads represented suspected cases of trafficking. “I have personally been told many times by law-enforcement agents that Craigslist is by far the most responsive Internet company that they deal with,” Powell said.52 He continued:

We participate actively in the cyber tip line program administered by the National Center for Missing & Exploited Children, and ads that meet NCMEC’s reporting guidelines are reported immediately. Moreover, we have been advised by NCMEC that we are the only such participant making direct reports among countless other venues that carry adult service ads. We have assisted sweeps, anti trafficking sweeps by the FBI and have been credited by agents with helping make those sweeps successful. We have engineered special tools to facilitate the work of NCMEC and law enforcement. These include creation of multiple special search interfaces that facilitate the search for missing children across all Craigslist sites.53

In his testimony, Powell announced that Craigslist had permanently closed its Adult Services section in the United States, with no plans to reopen the section.54 By December 2010, Craigslist closed all Adult Services sections worldwide.

The Craigslist case is striking because of (1) the lack of credible empirical research and aggregate data on trafficking and online technologies informing the debate, (2) the lack of more cooperative cross-sector partnerships and coordination, and (3) a missed opportunity to explore more creative solutions to the problem of trafficking online.


  1. At the end of the reporting period, only three states had yet to enact anti-trafficking laws: West Virginia, Wyoming, and Massachusetts. In Massachusetts, anti-trafficking legislation had passed but had yet to be signed into law. ^
  2. U.S. Department of State, Trafficking in Persons Report, June 2011, 373. ^
  3. Carrie Baker, “Jailing Girls for Men’s Crimes,” Ms. Magazine, December 8, 2010, One such example is the case of 13-year-old B.W., who was arrested in Texas for offering to perform an illegal sex act on an undercover officer, booked as an adult, and convicted, despite a state law that persons under 14 cannot consent to sex. The Texas Supreme Court reversed the decision on appeal, noting, “Children are the victims, not the perpetrators, of child prostitution.” In the Matter of B.W., 313 S.W.3d 818, 826 (Tex. 2010). ^
  4. Safe Harbor for Exploited Children N.Y. SOC. SERV. LAW § 447-a (McKinney 2008) ^
  5. For example, see An Act Providing a Safe Harbor for Exploited Children CONN. PUB. ACT 10-115. ^
  6. “These numbers do not reflect prosecutions of cases involving the commercial sexual exploitation of children that were brought under statutes other than the TVPA’s sex trafficking provision.… Traffickers were also prosecuted under a myriad of state laws, but no comprehensive data is available on state prosecutions and convictions.” U.S. Department of State, Trafficking in Persons Report, June 2011, 373. ^
  7. Ibid. ^
  8. Several sources were used to gather evidence of trafficking cases involving social media and online classified ads. Searches were limited to federal trafficking cases, as researching state cases of trafficking poses a particular challenge, namely accounting for the range of criminal charges that could apply to trafficking cases, which vary by state. ^
  9. Victims of Trafficking and Violence Protection Act of 2000, 18 U.S.C. § 1590 (October 28, 2000), addresses “trafficking with respect to peonage, slavery, involuntary servitude, or forced labor,” and 18 U.S.C. § 1591 addresses “sex trafficking of children or by force, fraud, or coercion.” ^
  10. Anna Park, regional attorney for the Equal Employment Opportunity Commission, telephone interview by CCLP research staff, March 7, 2011. ^
  11. U.S. Equal Employment Opportunity Commission (EEOC), “Employment Discrimination Laws ‘New Frontier’ in War Against Human Labor,” press release, January 19, 2011, ^
  12. EEOC, “EEOC Resolves Slavery and Human Trafficking Suit Against Trans Bay Steel for an Estimated $1 Million,” press release, December 8, 2006, EEOC v. Trans Bay was resolved in December 2006, with the parties reaching a settlement providing compensation and monetary relief to the Thai workers. ^
  13. EEOC Meeting, Human Trafficking and Forced Labor, January 19, 2011, (written testimony of Anna Park, EEOC regional attorney). ^
  14. Ibid. ^
  15. U.S. Attorney’s Office in Atlanta, telephone interview by CCLP research staff, March 14, 2011. ^
  16. As Secretary of State Hillary Clinton noted upon the release of the 2011 TIP Report, “Because of the ease of transportation and the global communications that can reach deep into villages with promises and pictures of what a better life might be, we now see that more human beings are exploited than before.” Hillary Rodham Clinton, “Remarks on the Release of the 2011 Trafficking in Persons Report,” June 27, 2011, U.S. Department of State, ^
  17. Victims of Trafficking and Violence Protection Act of 2000, 22 U.S.C. § 7102 (October 28, 2000). ^
  18. U.S. Immigration and Customs Enforcement, “Maryland man pleads guilty in sex trafficking conspiracy involving 3 minor girls,” news release, July 16, 2009,^
  19. U.S. Department of Justice, United States Attorney James T. Jacks, North District of Texas, “Dallas Felon Admits to Sex Trafficking a Minor and Possessing an Assault Rifle,” press release, January 18, 2011, ^
  20. Federal Bureau of Investigation, Jacksonville Division, “Jury Finds New York Man Guilty of Sex Trafficking Women by Force, Threats of Force, and Fraud,” press release, February 17, 2011, For another example, see U.S. v. Fuertes, 2011 WL 607391 (11th Cir., Feb. 22, 2011) at *3, in which the defendant advertised the sexual services of his underage victim on Backpage. ^
  21. Federal Bureau of Investigation, New York Field Office, “Last of 14 Gambino Crime Family Members and Associates Plead Guilty to Racketeering, Murder Conspiracy, Extortion, Sex Trafficking, and Other Crimes,” press release, January 10, 2011, ^
  22. Federal Bureau of Investigation, New York Field Office, “Nine Gambino Crime Family Members Sentenced in Manhattan Federal Court for Racketeering, Murder Conspiracy, Extortion, Sex Trafficking, and Other Crimes,” press release, May 12, 2011, Preet Bahara, the U.S. attorney for the Southern District of New York, “said the sex trafficking reflected perhaps ‘a new low for the Gambino family.’” Benjamin Weiser, “Charges Called ‘New Low’ for Gambinos,” New York Times, April 20, 2010, ^
  23. U.S. Attorney’s Office in Atlanta, telephone interview by CCLP research staff, March 14, 2011. ^
  24. Ibid. ^
  25. Federal Bureau of Investigation, Los Angeles Division, “Man Pleads Guilty and Is Sentenced to 17½ Years in Federal Prison for Sex Trafficking of Minors,” press release, June 10, 2010, ^
  26. Federal Bureau of Investigation, Atlanta Division, “Pair Indicted, Appear in Court for Sex Trafficking of a Minor,” press release, April 16, 2009, For details of sentencing, see Kimathi Lewis, “Arrests made in child sex crimes as agencies join forces,”, August 6, 2010, ^
  27. Federal Bureau of Investigation, Atlanta Division, “Pimp Who Claimed to Be a Modeling Agent Sentenced to Prison,” press release, June 4, 2009, ^
  28. U.S. Attorney’s Office in Atlanta, telephone interview by CCLP research staff, March 14, 2011. ^
  29. Retired LAPD Detective Keith Haight described Los Angeles as “the runaway capital of the world.” “Starting out young in the world’s oldest profession: children prostitutes in L.A.,” Pat Morrison, Southern California Public Radio, October 21, 2010, ^
  30. U.S. Department of State, Trafficking in Persons Report, June 2011, 372. ^
  31. Federal Bureau of Investigation, Seattle, “Tacoma Felon Sentenced to 13 Years in Prison for Sex Trafficking Offenses,” Department of Justice press release, May 11, 2010, ^
  32. Federal Bureau of Investigation, Seattle, “Army Sergeant Sentenced to 11 Years in Prison for Sex Trafficking Juveniles,” Department of Justice press release, October 26, 2010, Minor Sex Trafficking: Hearings on H.R. 5575, Before the Subcommittee on Crime, Terrorism, and Homeland Security, 111th Cong. 154 (2010). ^
  33. “Human Rescue Trafficking Project,” U.S. Attorney’s Office for the Western District of Missouri, last accessed June 27, 2011, The Human Trafficking Rescue Project (HTRP) was launched in 2006. This federal taskforce is comprised of the Federal Bureau of Investigation, U.S. Immigration and Customs Enforcement (ICE), the Department of Labor, and two local Missouri police departments. ^
  34. U.S. Immigration and Customs Enforcement, “Kansas man gets 15 years in prison for attempted sex trafficking of a child,” news release, December 1, 2009, ^
  35. “The Human Trafficking Rescue Project conducted a sting operation [in March 2009] which targeted local customers who solicit pimps to engage in commercial sex acts with children. The ‘children’ were advertised online at Craig’s List [sic]; no real children were actually involved in the sting.” Ibid. ^
  36. Victims of Trafficking and Violence Protection Act of 2000, 18 U.S.C. § 1591(a)(1) (October 28, 2000), reads “(a) Whoever knowingly—(1) in or affecting interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States, recruits, entices, harbors, transports, provides, obtains, or maintains by any means a person” (emphasis added). ^
  37. United States v. Myers, 2011 WL 2391306 (11th Cir., June 15, 2011), at *6. ^
  38. Ibid. at *8. ^
  39. While Craigslist CEO Jim Buckmaster made it clear that “[w]e do not want illegal activity on the site,” he explained that it was nearly impossible for its small staff to audit the millions of postings. Bruce Lambert, “As Prostitutes Turn to Craigslist, Law Takes Notice,” New York Times, September 5, 2007, Craigslist also maintained that it was exempt from any legal obligation to address the advertisements under its site, citing §230 of the Communications Decency Act of 1996, which states, “No provider or user of an interactive computer service shall be treated as the publisher or speaker of any information provided by another information content provider.” Communications Decency Act of 1996, 47 U.S.C. §230 (1998). ^
  40. As Elizabeth McDougall, counsel to Craigslist on online safety, security, and abuse issues, noted, “[I]n terms of voluntary action by craigslist, when craigslist implemented these measures, credit card verification and phone verification, a lot of that started to migrate over to the therapeutic services category on craigslist, and voluntarily craigslist implemented these same measures there.” Domestic Minor Sex Trafficking: Hearings on H.R. 5575, Before the Subcommittee on Crime, Terrorism, and Homeland Security, 111th Cong. 175 (2010) (testimony of Elizabeth McDougall). ^
  41. Brad Stone, “Under Pressure, Craigslist to Remove ‘Erotic’ Ads,” New York Times, May 13, 2009, ^
  42. Evan Hansen, “Censored! Craigslist Adult Services Blocked in U.S.,”, September 4, 2010, ^
  43. Melissa Gira Grant, “The Craigslist Sex Panic,” Slate, May 27, 2009,; Alan Duke, “Official: Craigslist to replace ‘blatant Internet brothel’,” CNN, May 13, 2009, “Misuse of Craigslist for criminal purposes is utterly unacceptable, and Craigslist will continue to work with its partners in law enforcement and at nongovernmental organizations until it is eliminated,” said Craigslist CEO Jim Buckmaster. Brad Stone, “Sex Ads Seen Adding Revenue to Craigslist,” New York Times, April 25, 2010, ^
  44. Brad Stone, “Sex Ads Seen Adding Revenue to Craigslist,” New York Times, April 25, 2010, ^
  45. The Advocates for Human Rights, “Human Rights Organization Declines Craigslist Grant,” press release, May 4, 2010, ^
  46. Richard Blumenthal, Attorney General of Connecticut, et al., letter to Jim Buckmaster, CEO and Craig Newmark, Founder, Craigslist, RE: Adult Services Section of Craigslist, August 24, 2010, In an example of action pertaining to Backpage, a group of 45 state attorneys general sent a letter to Samuel Fifer, counsel for, “concerning the company’s facilitation of sexual exploitation of children, and prostitution.” The letter included a request for more information about the company’s policies and practices. George Jepson, Attorney General of Connecticut, et. al, letter to Samuel Fifer, counsel,, August 31, 2011,^
  47. The Associated Press, “Illinois Sheriff Sues Craigslist,” New York Times, March 5, 2009, ^
  48. Dart v. Craigslist, Inc., 665 F. Supp. 2d 961 (N.D. Ill. 2009); Editorial, “A Win for Internet Speech,” The New York Times, October 26, 2009, In a more recent case brought against an online classified site for its alleged role in trafficking online, a 15-year-old sex trafficking victim sued Village Voice Media, claiming that §230 of the Communications Decency Act does not apply. Complaint for Damages, M.A. v. Village Voice Media Holdings, LLC., Case 4:10-cv-01740 (E. Dist. Mo. Sept. 16, 2010).On August 15, 2011, U.S. Magistrate Judge Thomas Mummert dismissed the case, stating, “Plaintiff artfully and eloquently attempts to phrase her allegations to avoid the reach of §230. Those allegations, however, do not distinguish the complained-of actions of Backpage from any other website that posted content that led to an innocent person’s injury. Congress has declared such websites to be immune from suits arising from such injuries. It is for Congress to change the policy that gave rise to such immunity.” M.A v. Village Voice Media Holdings, LLC., No. 4:2010cv01740, 2011 U.S. Dist. LEXIS 90588 (E. Dist. Mo. August 15, 2011), at *48-49. ^
  49. Domestic Minor Sex Trafficking: Hearings on H.R. 5575, Before the Subcommittee on Crime, Terrorism, and Homeland Security, 111th Cong. (2010). On the eve of the hearing, 100 anti-trafficking organizations and experts sent a letter to Craig Newmark, founder of Craigslist, and Jim Buckmaster, CEO of Craigslist, calling for the closure of the Adult Services sections of the site worldwide. Mark Logan, executive director, Polaris Project, letter to Craig Newmark and Jim Buckmaster, “Craigslist Must Complete the Job,” September 14, 2011, ^
  50. That same month, Craigslist removed the adult sections in U.S. cities due to pressure by federal lawmakers, anti-trafficking groups, and the media. The section was first blocked on September 3, 2010 and replaced with a black label with the word “censored,” which was later removed. CNN Wire Staff, “Adult services censored on Craigslist,” CNN, September 4, 2010, ^
  51. Domestic Minor Sex Trafficking: Hearings on H.R. 5575, Before the Subcommittee on Crime, Terrorism, and Homeland Security, 111th Cong. 10 (2010) (statement of Rep. Jackie Speier). ^
  52. Domestic Minor Sex Trafficking: Hearings on H.R. 5575, Before the Subcommittee on Crime, Terrorism, and Homeland Security, 111th Cong. 169 (2010) (testimony of William Clinton Powell). ^
  53. Ibid. ^
  54. Powell also stated, “Those who formerly posted ads in the adult services category will now have to advertise elsewhere, and in fact, there is evidence that this process began immediately.” Ibid. ^