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A lawsuit against consumer review site Yelp! has yielded an opinion that demonstrates the breadth of the protection afforded interactive service providers under Section 230 of the Communications Decency Act. In Levitt v. Yelp! Inc., 2011 U.S. Dist. LEXIS 124082 (N.D. Cal. Oct. 26, 2011), a group of putative class action plaintiffs filed an action against the site under Section 17200 of the California Business and Professions Code, claiming that the site manipulated its consumer review functionality to extort advertising revenues from the plaintiff businesses.

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