tech companies petitioned the case to the Supreme Court. California Case law Numerous cases involving Section 230 have been heard in the judiciary system since its introduction, many which are rote applications of Section 230. The following is a partial list of legal cases that have been established as case law that have influenced the interpretation of Section 230 in subsequent cases or have led to new legislation around Section 230. Defamatory information Zeran v. AOL, 129 F.3d 327 (4th Cir. 1997). Immunity was upheld against claims that AOL unreasonably delayed in removing defamatory messages posted by third party, failed to post retractions, and failed to screen for similar postings. Blumenthal v. Drudge, 992 F. Supp. 44, 49–53 (D.D.C. 1998). The court upheld AOL's immunity from liability for defamation. AOL's agreement with the contractor allowing AOL to modify or remove such content did not make AOL the "information content provider" because the content was created by an independent contractor. The Court noted that Congress made a policy choice by "providing immunity even where the interactive service provider has an active, even aggressive role in making available content prepared by others." Carafano v. Metrosplash.com, 339 F.3d 1119 (9th Cir. 2003). The court upheld immunity for an Internet dating service provider from liability stemming from third party's submission of a false profile. The plaintiff, Carafano, claimed the false profile defamed her, but because the content was created by a third party, the website was immune, even though it had provided multiple choice selections to aid profile creation. Batzel v. Smith, 333 F.3d 1018 (9th Cir. 2003). Immunity was upheld for a website operator for distributing an email to a listserv where the plaintiff claimed the email was defamatory. Though there was a question as to whether the information provider intended to send the email to the listserv, the Court decided that for determining the liability of the service provider, "the focus should be not on the information provider's intentions or knowledge when transmitting content but, instead, on the service provider's or user's reasonable perception of those intentions or knowledge." The Court found immunity proper "under circumstances in which a reasonable person in the position of the service provider or user would conclude that the information was provided for publication on the Internet or other 'interactive computer service'." Green v. AOL, 318 F.3d 465 (3rd Cir. 2003). The court upheld immunity for AOL