With regard to the second and third theories of conflict however, the court found that the CDA did preempt the state laws. Based on the findings of "Cubby, Inc. v. CompuServe Inc.", which found that CompuServe "was a distributor for the purposes of defamation liability," Zeran contended that AOL was a distributor of information, not a publisher, and because §230(c)(1) of the CDA spoke specifically to publishers, Zeran alleged that there was not a conflict between the two statutes. The court found, however, that distributors are a subset of publishers, and that as a result the CDA conflicted with the state defamation law, thus preempting it.