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.
The risk there is in trying to be everything
and nothing at the same
time. The safest approach remains in keeping the publishing and ISP
functions as far apart as possible.