A decade ago, the Supreme Court was almost ready to confer First Amendment protection on the "Internet" believing that it was sufficiently benign. Little did everyone anticipate how different that rosy view might seem today. Several troubling developments have occurred within the past months. Megan Meier, a 13-year-old in Missouri, was apparently driven to commit suicide by taunts and cruel messages from an adult neighbor on MySpace. Due to the troubling effects of cyberbullying, lawmakers in at least two states have recently sponsored "cyberbullying" laws that would impose criminal liability on the basis of "intent to coerce, intimidate, harass, or cause substantial emotional distress." In this article, the author discusses why the prospect of liability that arise from cases of cyberbullying seemed problematic under U.S. law. He also discusses how there seem little that concerned institutions can do to prevent cyberbullying.