In Atlantic Recording Corporation et al. v. Project Playlist, Inc. 2009 WL 766224 (S.D.N.Y.) six of the world's largest record companies sued the defendant, Project Playlist, Inc. (“Project Playlist”), for copyright infringement in the District Court for the Southern District of New York. (See Complaint for Damages and Injunctive Relief). The Plaintiffs' claims stemmed from Project Playlist's permitting users to create playlists through links to music featured on other websites without first obtaining the approval or licensing rights from the sites. Project Playlist moved for dismissal of the Plaintiffs’ state law claims for common law copyright infringement and unfair competition on the grounds that such claims were barred by the 47 U.S.C. § 230 (the Communications Decency Act, hereinafter the “Act”). The Court held that though Project Playlist was an Internet service provider under the Act, it was excluded from the statutory immunity afforded by Section 230(c)(2) because the Plaintiffs' claims arose from state intellectual property law and fell under the exception set forth in Section 230(e)(2).