Zeran v. America Online, Inc.

After the 1995 Oklahoma City bombing, an unknown America Online (AOL) (defendant) user posted ads for tasteless bombing-themed t-shirts and listed Zeran's (plaintiff) phone number for orders. Zeran had nothing to do with the posts but was flooded with harassing calls. He sued AOL for defamation, essentially for failing to remove the posts and stop the harm. The district court granted AOL summary judgment, and Zeran appealed.

Whether an interactive computer service provider may be treated as the publisher of defamatory information posted by a third party, or is instead immune under Section 230 of the Communications Decency Act.