an action based on promissory estoppel. As of mid-2016, courts have issued conflicting decisions regarding the scope of the intellectual property exclusion set forth in §230(e)(2). For example, in Perfect 10, Inc. v. CCBill, LLC, the 9th Circuit Court of Appeals ruled that the exception for intellectual property law applies only to federal intellectual property claims such as copyright infringement, trademark infringement, and patents, reversing a district court ruling that the exception applies to state-law right of publicity claims. The 9th Circuit's decision in Perfect 10 conflicts with conclusions from other courts including Doe v. Friendfinder. The Friendfinder court specifically discussed and rejected the lower court's reading of "intellectual property law" in CCBill and held that the immunity does not reach state right of publicity claims. Two bills passed since the passage of Section 230 have added further limits to its protections. The Digital Millennium Copyright Act in 1998, service providers must comply with additional requirements for copyright infringement to maintain safe harbor protections from liability, as defined in the DMCA's Title II, Online Copyright Infringement Liability Limitation Act. The Stop Enabling Sex Traffickers Act (the FOSTA-SESTA act) of 2018 eliminated the safe harbor for service providers in relationship to federal and state sex trafficking laws. Background and passage Prior to the Internet, case law was clear that a liability line was drawn between publishers of content and distributors of content; a publisher would be expected to have awareness of material it was publishing and thus should be held liable for any illegal content it published, while a distributor would likely not be aware and thus would be immune. This was established in the 1959 case, Smith v. California, where the Supreme Court ruled that putting liability on the provider (a book store in this case) would have "a collateral effect of inhibiting the freedom of expression, by making the individual the more reluctant to exercise it." In the early 1990s, the Internet became more widely adopted and created means for users to engage in forums and other user-generated content. While this helped to expand the use of the Internet, it also resulted in a number of legal cases putting service providers at fault for the content generated by its users. This concern was raised by legal challenges against CompuServe and Prodigy, which were early service providers at that time. CompuServe stated it would not attempt to regulate what users