The "Marsh" holding at first appears somewhat narrow and inapplicable today because of the disappearance of company towns from the United States, but it was raised in the somewhat high-profile 1996 cyberlaw case, "Cyber Promotions v. America Online", 948 F. Supp. 436, 442 (E.D. Pa. 1996). Cyber Promotions wished to send out "mass email advertisements" to AOL customers. AOL installed software to block those emails. Cyber Promotions sued on free speech grounds and cited the "Marsh" case as authority for the proposition that even though AOL's servers were private property, AOL had opened them to the public to a such a degree that constitutional free speech protections could be applied. The federal district court disagreed, thereby paving the way for spam filters at the Internet service provider level.