Where One Marketplace Closes, (Hopefully) Another Won\u27t Open: In Defense of FOSTA

Since federal law first acknowledged the crime of sex trafficking in 2000, the internet has exploded—and sex traffickers have taken note. Traffickers have gained a platform to sell their victims to a much larger audience and with greater ease. Posting victims’ advertisements online allows traffickers to drastically expand their customer base beyond the traditional street corner. Despite congressional attempts to criminalize sex traffickers and their beneficiaries since 2000, the internet persists as an effective conduit for sex traffickers to find customers. In 2018, Congress sought to remedy this by passing legislation that expanded criminal and civil liability to websites that knowingly participate in sex trafficking by hosting sex trafficking advertisements. In part, the Allow States and Victims to Fight Online Sex Trafficking Act (FOSTA) amends a law that was widely understood to provide websites with total immunity from claims arising out of third-party content. Concerned with the potential for criminal prosecutions, internet service providers criticize FOSTA as an infringement on their First Amendment right to free speech. They argue that the law forces them to censor third-party users’ content and that it improperly extends to legal speech. The First Amendment generally does not restrict the content of speech, however, and its protections do not extend to speech that solicits crime. This Note will argue that FOSTA does not violate the First Amendment and is constitutionally sound at its core because sex traffickers’ advertisements solicit crime

Evaluation of prognostic risk models for postoperative pulmonary complications in adult patients undergoing major abdominal surgery: a systematic review and international external validation cohort study

Background Stratifying risk of postoperative pulmonary complications after major abdominal surgery allows clinicians to modify risk through targeted interventions and enhanced monitoring. In this study, we aimed to identify and validate prognostic models against a new consensus definition of postoperative pulmonary complications. Methods We did a systematic review and international external validation cohort study. The systematic review was done in accordance with the Preferred Reporting Items for Systematic Reviews and Meta-Analyses guidelines. We searched MEDLINE and Embase on March 1, 2020, for articles published in English that reported on risk prediction models for postoperative pulmonary complications following abdominal surgery. External validation of existing models was done within a prospective international cohort study of adult patients (≥18 years) undergoing major abdominal surgery. Data were collected between Jan 1, 2019, and April 30, 2019, in the UK, Ireland, and Australia. Discriminative ability and prognostic accuracy summary statistics were compared between models for the 30-day postoperative pulmonary complication rate as defined by the Standardised Endpoints in Perioperative Medicine Core Outcome Measures in Perioperative and Anaesthetic Care (StEP-COMPAC). Model performance was compared using the area under the receiver operating characteristic curve (AUROCC). Findings In total, we identified 2903 records from our literature search; of which, 2514 (86·6%) unique records were screened, 121 (4·8%) of 2514 full texts were assessed for eligibility, and 29 unique prognostic models were identified. Nine (31·0%) of 29 models had score development reported only, 19 (65·5%) had undergone internal validation, and only four (13·8%) had been externally validated. Data to validate six eligible models were collected in the international external validation cohort study. Data from 11 591 patients were available, with an overall postoperative pulmonary complication rate of 7·8% (n=903). None of the six models showed good discrimination (defined as AUROCC ≥0·70) for identifying postoperative pulmonary complications, with the Assess Respiratory Risk in Surgical Patients in Catalonia score showing the best discrimination (AUROCC 0·700 [95% CI 0·683–0·717]). Interpretation In the pre-COVID-19 pandemic data, variability in the risk of pulmonary complications (StEP-COMPAC definition) following major abdominal surgery was poorly described by existing prognostication tools. To improve surgical safety during the COVID-19 pandemic recovery and beyond, novel risk stratification tools are required. Funding British Journal of Surgery Society