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  1. Although Mindspring recognizes the appeal of the Court's reading of Section 230(e)(2), (Mindspring's Mem. at 6), Mindspring nevertheless argues that immunity from Plaintiff's claims would not 'limit' any law pertaining to intellectual property, since liability for trademark infringement has never previously been imposed on an ISP in this sitmtion , (
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name in splashy, sexy New York glamour-girl gucci hobo designs."> mean that gucci hobo people have suddenly become a Even assuming it were appropriate to employ additional cannons of construction, the Court's interpretation of Section 230(e)(2) would not change. Section 230's legislative history provides no clues as to the meaning of the unadorned 17 words that comprise [Section 230(e)(2)]. (Mindspring's Mem. at 6-7).

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  3. Mindspring suggests that [t]he purpose of the 1988 amendments was to extend the innocent infringer defense to radio and television, but that "Congress could not have contemplated applying the Lanham Act to commercial websites (or to ISPs) in 1988, since the World Wide Web did not yet exist, nor did the business of providing Internet access. (Mindspring's reply at 6.) Plaintiff (persuasively) counters that the definition of electronic communication set forth in the Electronic Communications Privacy Act precisely describes the typical commercial internet website such as maintained by Hall and Associates...with the aid of Mindspring's facilities gucci hat and services. (Pl's. Mem. at 12.)
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