Maybe, but one thing I noticed recently is that
[[Section 230]] of the
CDA doesn't say that a service provider *isn't* a publisher, it says
they won't "be treated as" a publisher. That's a subtle but perhaps
significant difference.
That's a very significant difference. It doesn't say "a provider which
is not a publisher", it just says "a provider". Based on that, I would
say the WMF is the publisher of Wikipedia, but it isn't liable as
publisher for user generated content.