Plaintiff Goddard sued Google for displaying third-party ads that led to allegedly fraudulent mobile subscription services.

The plaintiffs accused Google of furthering unlawful activity because its Keyword Tool suggested to advertisers of mobile content that they include the word "free" in advertisements including the word "ringtone." The court held that CDA § 230 barred the claim, because the Keyword Tool was a neutral tool that "does nothing more than provide options that advertisers may adopt or reject at their discretion."