On April 25, 1995, six days after the Oklahoma City bombing, a message was anonymously posted on America Online's (AOL) "Michigan Military Movement" bulletin board advertising items with slogans glorifying the bombing of the Alfred P. Murrah Federal Building. These items included slogans such as, "Visit Oklahoma ... It's a BLAST!!!", "Putting the kids to bed ... Oklahoma 1995", and "McVeigh for President 1996". Persons interested in making a purchase were instructed to call the plaintiff, Kenneth M. Zeran, whose home phone number was posted in the message but who had neither posted the message nor had anything to do with the content of the ad. Shortly after the posting of the messages, Zeran began receiving a barrage of threatening calls. He contacted AOL to have the message removed, which they soon did.