In Zeran v. America Online, Inc. (4th Cir. 1997) 129 F.3d 327, the plaintiff discovered that someone had falsely advertised on America Online that he was selling T-shirts containing tasteless slogans about the 1995 bombing of the Oklahoma City federal building. The plaintiff complained that America Online failed to remove the postings immediately, failed to notify other subscribers of the message's false nature and failed to effectively screen future defamatory material. The trial court granted America Online's motion for judgment on the pleadings and the Fourth Circuit affirmed, holding that immunity is extended even when a provider is notified of objectionable content on its site. The court reasoned: "Congress' purpose in providing the 230 immunity was thus evident. Interactive computer services have millions of users.The amount of information communicated via interactive computer services is therefore staggering. The specter of tort liability in an area of such prolific speech would have an obvious chilling effect. It would be impossible for service providers to screen each of their millions of postings for possible problems. Faced with potential liability for each message republished by their services, interactive computer service providers might choose to severely restrict the number and type of messages posted. Congress considered the weight of the speech interests implicated and chose to immunize service providers to avoid any such restrictive effect." (Zeran, at p. 331.) The court held section 230, by its "plain language," created a federal immunity to any cause of action that would make interactive service providers liable for information originating with a third party user of the service. ( Id. at p. 330.) "Specifically, 230 precludes courts from entertaining claims that would place a computer service provider in a publisher's role. Thus, lawsuits seeking to hold a service provider liable for its exercise of a publisher's traditional editorial functions--such as deciding whether to publish, withdraw, postpone or alter content--are barred." (Zeran, supra, at p. 330.) Reiterating Congress's findings and policy statements in section 230(a), (b), the court observed: "Congress recognized the threat that tort-based lawsuits pose to freedom of speech in the new and burgeoning Internet medium. The imposition of tort liability on service providers for the communications of others represented, for Congress, simply another form of intrusive government regulation of speech. Section 230 was enacted, in part, to maintain the robust nature of Internet communication and, accordingly, to keep government interference in the medium to a minimum. . . . None of this means, of course, that the original culpable party who posts defamatory messages would escape accountability. While Congress acted to keep government regulation of the Internet to a minimum, it also found it to be the policy of the United States 'to ensure vigorous enforcement of Federal criminal laws to deter and punish trafficking in obscenity, stalking, and harassment by means of computer.' . Congress made a policy choice, however, not to deter harmful online speech through the separate route of imposing tort liability on companies that serve as intermediaries for other parties' potentially injurious messages." (Zeran, supra, at pp. 330-331.)