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I am not a lawyer, but my understanding is that this generally falls under Section 230, as you can make the same argument about Comcast, AT&T, et.al. who lets the bytes go over their infrastructure.

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But the difference is that Comcast, AT&T, et.al can say, jameskilton was using this IP. The VPN is saying, I don't know.

That's only a problem if the VPN is in a jurisdiction with data retention laws: https://en.wikipedia.org/wiki/Data_retention

What if you get the same IP time and again?

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