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High Severity

Pre-Publication Fact-Checking Kills Digital Platforms

This provision requires all internet intermediaries and content creators to fact-check information before publication and establishes mandatory fact-checking desks for platforms. For user-generated content platforms processing thousands or millions of posts daily, pre-publication verification is technically and economically impossible without either massive delays that destroy user experience or automated systems that will block legitimate speech. This directly contradicts the safe harbor protections in 77, which state intermediaries have no general monitoring obligation. Combined with the licensing prerequisite and training requirements, this creates insurmountable barriers for startups and smaller platforms while giving the Division discretionary power to exclude competitors through certification denial.