No. 13-5946 Jones v. Dirty World Entm’t Recordings, et al. Page 18 even intimate, that Consumeraffairs.com contributed to the allegedly fraudulent nature of the comments at issue.” Id. at 257 (internal quotation marks omitted). In Accusearch, Accusearch operated a website that sold the confidential information of individuals, including their telephone records, which the website paid researchers to obtain. 570 F.3d at 1190. The Federal Trade Commission brought suit against the website operator to curtail its sale of confidential information and to disgorge its profits from the sale of information in telephone records. Id. Accusearch claimed immunity under the CDA, arguing that it merely displayed the allegedly illegal conduct that originated from its third-party researchers. Id. The panel rejected this argument and held that the website operator developed the confidential telephone records within the meaning of the CDA. The panel cited Roommates’s material contribution test and found “[t]hat language applies to Accusearch’s role in this case.” Id. at 1200 (citing Roommates, 570 F.3d at 1168). The Accusearch panel reasoned that “[b]y paying its researchers to acquire telephone records, knowing that the confidentiality of the records was protected by law, it contributed mightily to the unlawful conduct of its researchers.” Id. The panel noted that “the offensive postings were Accusearch’s raison d’etre and it affirmatively solicited them.” Id. It thus found that “Accusearch’s actions were not ‘neutral’ with respect to generating offensive content; on the contrary, its actions were intended to generate such content.” Id. at 1201. Accordingly, the panel held that “Accusearch is not entitled to immunity under the CDA.” Id. Other circuits, while not explicitly relying on Roommates’s material contribution test, have issued decisions consistent with it. See, e.g., Johnson, 614 F.3d at 791 (holding that a website hosting company was immune to state tort claims grounded on unwelcome content posted to a client’s website); Chicago Lawyers’ Comm., 519 F.3d at 671 (holding that craigslist.com was immune to fair housing claims based on discriminatory listings posted by third parties); Green, 318 F.3d at 471 (holding that AOL was immune to state tort claims grounded on third-party content); Ben Ezra, 206 F.3d at 984−85 (holding that defendant was immune to the defamation claim when it made its own editorial decisions with respect to thirdparty information published on its website); Zeran, 129 F.3d at 330−35.