against allegations of negligence. Green claimed AOL failed to adequately police its services and allowed third parties to defame him and inflict intentional emotional distress. The court rejected these arguments because holding AOL negligent in promulgating harmful content would be equivalent to holding AOL "liable for decisions relating to the monitoring, screening, and deletion of content from its network -- actions quintessentially related to a publisher's role." Barrett v. Rosenthal, 40 Cal. 4th 33 (2006). Immunity was upheld for an individual internet user from liability for republication of defamatory statements on a listserv. The court found the defendant to be a "user of interactive computer services" and thus immune from liability for posting information passed to her by the author. MCW, Inc. v. badbusinessbureau.com(RipOff Report/Ed Magedson/XCENTRIC Ventures LLC) 2004 WL 833595, No. Civ.A.302-CV-2727-G (N.D. Tex. April 19, 2004). The court rejected the defendant's motion to dismiss on the grounds of Section 230 immunity, ruling that the plaintiff's allegations that the defendants wrote disparaging report titles and headings, and themselves wrote disparaging editorial messages about the plaintiff, rendered them information content providers. The Web site, www.badbusinessbureau.com, allows users to upload "reports" containing complaints about businesses they have dealt with. Hy Cite Corp. v. badbusinessbureau.com (RipOff Report/Ed Magedson/XCENTRIC Ventures LLC), 418 F. Supp. 2d 1142 (D. Ariz. 2005). The court rejected immunity and found the defendant was an "information content provider" under Section 230 using much of the same reasoning as the MCW case. Barnes v. Yahoo!, Inc. 570 F.3d 1096 (9th Cir. 2009) The court rejected immunity for the defendant when failing to uphold a promissory estoppel claim related to third-party content that they were otherwise immune from; in this case, Yahoo! had promised to remove nude photos of the plaintiff placed maliciously on the site by an ex-partner but had failed to do so. While the Ninth Circuit ultimately dismissed the case since Yahoo! would not have been liable for the photos under Section 230, their promissory estoppel makes them a "publisher or speaker" under Section 230. False information Gentry v. eBay, Inc., 99 Cal. App. 4th 816, 830 (2002). eBay's immunity was upheld for claims based on forged autograph sports items purchased on the auction site. Ben Ezra, Weinstein & Co. v. America Online, 206 F.3d 980, 984–985 (10th Cir. 2000), cert. denied, 531 U.S. 824 (2000). Immunity for AOL was upheld against liability for a user's posting of