google argued that under section 230 of the communications decency act, as an "interactive service provider", it has immunity from the plaintiff's complaint. under the statute, if google satisfies the requirements for being an interactive computer service, then it has immunity for acting as a publisher of information provided by a third-party. o'kroley argued that the act of summarizing a non-defamatory article into a defamatory summary created new content and turned google into an information content provider and thus losing its protected status. however, courts have found the immunities provided under the statute as "quite robust." the magistrate judge reviewing the case found that google's automated editing and summarization process falls under the role of a publisher and thus google has immunity from liability. based on this conclusion, the district judge upheld the magistrate's recommendation and granted google's motion to dismiss the complaint.