In Lunney v. Prodigy Servs. Co. (94 NY2d 242) an imposter opened several accounts with Prodigy Services Company (an Internet service provider or ISP) under the plaintiff's name and thereafter posted two vulgar messages attributed to Lunney upon a Prodigy bulletin board accessible by the Internet and sent a threatening e-mail in Lunney's name to a third person. Lunney sued Prodigy for defamation and negligence. The lower court denied Prodigy's dismissal motion and the Appellate Division, in reversing, held that Prodigy was protected by the common-law privilege recognized in Anderson v. New York Tel. Co. (35 NY2d 746). In Lunney the Court of Appeals undertook a comparative analysis in which it examined the mode (e-mail and bulletin board posting) and methodology (use of an ISP) of dissemination against historical precedents. In so doing, the Court found e-mail to be "the day's evolutionary hybrid of traditional telephone line communications and regular postal service mail." Importantly, the Court went on to state: "Because Lunney's defamation action is grounded in New York common law, we evaluate it in accordance with our established tort principles (see, Foster v. Churchill, 87 NY2d 744, 751-752; Liberman v. Gelstein, 80 NY2d 429, 434). Although they were fashioned long before the advent of e-mail, these settled doctrines accommodate the technology comfortably, and with apt analogies (see generally, Miranda, Defamation in Cyberspace: Stratton Oakmont, Inc. v. Prodigy Services Co., 5 Alb LJ Sci & Tech 229, 237 [1996])." (Lunney v. Prodigy Servs. Co., 94 NY2d, at 248-249.)