No. 13-5946 Jones v. Dirty World Entm’t Recordings, et al. Page 10 2003); Ben Ezra, Weinstein, & Co. v. AOL, 206 F.3d 980, 984−85 (10th Cir. 2000); Zeran v. AOL, 129 F.3d 327, 328 (4th Cir. 1997). Furthermore, § 230(e)(3) provides that “[n]o cause of action may be brought and no liability may be imposed under any State or local law that is inconsistent with this section.” 47 U.S.C. § 230(e)(3). Section 230 marks a departure from the common-law rule that allocates liability to publishers or distributors of tortious material written or prepared by others. See Batzel, 333 F.3d at 1026−27. “Absent § 230, a person who published or distributed speech over the Internet could be held liable for defamation even if he or she was not the author of the defamatory text, and, indeed, at least with regard to publishers, even if unaware of the statement.” Id. (citing Stratton Oakmont, Inc. v. Prodigy Servs. Co., 1995 WL 323710 (N.Y. Sup. Ct. May 24, 1995) (pre-CDA case holding internet service provider liable for posting by third party on one of its electronic bulletin boards)). Congress, however, decided to treat the internet differently. Id. At its core, § 230 bars “lawsuits seeking to hold a service provider liable for its exercise of a publisher’s traditional editorial functions—such as deciding whether to publish, withdraw, postpone or alter content.” Zeran, 129 F.3d at 330. In Zeran, a case arising shortly after the enactment of the CDA, the panel considered a defamation claim against America Online (AOL) alleging “that AOL unreasonably delayed in removing defamatory messages posted by an unidentified third party, refused to post retractions of those messages, and failed to screen for similar postings thereafter.” Id. at 328. The Zeran court explained that the CDA squarely barred this claim. See id. at 330−35. By barring publisher-liability and notice-liability defamation claims lodged against interactive computer service providers, § 230 serves three main purposes. First, it “maintain[s] the robust nature of Internet communication and, accordingly, . . . keep[s] government interference in the medium to a minimum.” Id. at 330; see also 47 U.S.C. § 230(b)(2) (“It is the policy of the United States . . . to preserve the vibrant and competitive free market that presently exists for the Internet and other interactive computer services, unfettered by Federal or State regulation.”). Second, the immunity provided by § 230 protects against the “heckler’s veto” that would chill free speech. Without § 230, persons who perceive themselves as the objects of unwelcome speech on the internet could threaten litigation against interactive computer service