Vermont Statutes Annotated

Vt. Stat. Ann. tit. 09, § 2452 (2026)

Limitation

✓ current as of May 2026

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Subchapter 001 : GENERAL PROVISIONS

(Cite as: 9 V.S.A. § 2452)

§ 2452. Limitation

(a) Nothing in this chapter shall apply to the owner or publisher of a newspaper, magazine, publication, or printed matter, or to a provider of an interactive computer service, wherein an advertisement or offer to sell appears, or to the owner or operator of a radio or television station that disseminates an advertisement or offer to sell, when the owner, publisher, operator, or provider has no knowledge of the fraudulent intent, design, or purpose of the advertiser or offeror, and is not responsible, in whole or in part, for the creation or development of the advertisement or offer to sell.

(b) In this section, “interactive computer service” has the same meaning as in 47 U.S.C. § 230(f)(2). (Added 1967, No. 132, § 1, eff. April 17, 1967; amended 2015, No. 55, § 9.)

Notes of Decisions

Cited in 2 cases, 1998–2002 · leading case: Carter v. Gugliuzzi, 716 A.2d 17 (Vt. 1998).

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Carter v. Gugliuzzi, 716 A.2d 17 (Vt. 1998). “” 9 V.S.A. § 2452. Where remedial legislation contains an express limitation, we have generally declined to expand the exception beyond its plain terms.”

Repucci v. Lake Champagne Campground, Inc., 251 F. Supp. 2d 1235 (D. Vt. 2002). “” Vt. Stat. Ann. tit. 9, § 2452 (1993). More broadly, “derivative liability for consumer fraud cannot be imposed ‘absent direct participation in the unfair or deceptive acts, direct aid to the actor, or a principal/agent relationship.”

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