Google suggested "styrotrim," a trademark of Plaintiff, as a keyword to people bidding via adwords. This could make competitors of Plaintiff to appear above Plaintiff's business in Google's search results for the term. The court held that CDA 230 applied because suggesting a term but leaving the choice completely up to the bidders did not constitute Google producing any of the allegedly infringing content.

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By suggesting keywords to competing advertisers Defendant merely helps third parties to refine their content. This is tantamount to the editorial process protected by the CDA. Defendant's keyword suggestion tool hardly amounts to the participation necessary to disqualify it of CDA immunity. Rather it is a "neutral tool," that does nothing more than provide options that advertisers could adopt or reject at their discretion, thus entitling the operator to immunity.