I'm with you on the initial distinction, but I'm unconvinced about your targeting argument.
If you run a sub business, you're user-aligned. This should incentivise you to keep your subscribers safe, avoiding the moral hazards of 230 (and in line with legislative intent).
Thread · 4 tweets · 18 Jun 2020
If you run an ad business, you want volume and time spent. The rage clickers will engage 10x so that you're better off catering to them than trying to help those getting hurt, who are less likely to have disposable income anyway and so are inherently less valuable.
You also don't need data, at least not in the manner that it's traded now, to do targeting. There are plenty of contextual proxies. Some of us are big enough to do that entirely first party, too.
I would go for a different distinction: you get 230 protection when people pay you (a fair price) to publish. When you pay them, or just relay them, then you're a publisher.
Same effect, avoids issues with mixed business models.