Section 230 immunity is not unlimited. The statute specifically excepts federal criminal liability (§230(e)(1)), electronic privacy violations (§230(e)(4)) and intellectual property claims (§230(e)(2)). There is also no immunity from state laws that are consistent with 230(e)(3) though state criminal laws have been held preempted in cases such as Backpage.com, LLC v. McKenna and Voicenet Communications, Inc. v. Corbett (agreeing that "the plain language of the CDA provides ... immunity from inconsistent state criminal laws"). What constitutes "publishing" under the CDA is somewhat narrowly defined by the courts. The Ninth Circuit held that "Publication involves reviewing, editing, and deciding whether to publish or to withdraw from publication third-party content." Thus, the CDA does not provide immunity with respect to content that an interactive service provider creates or develops entirely by themselves.