The very first major problem to Section 230 itself was Zeran v. AOL, a 1997 scenario made the decision at the Fourth Circuit. Cox/Wyden's area grew to become Section 509 of the Telecommunications Act of 1996 and grew to become regulation as a new Section 230 of the Communications Act of 1934. The anti-indecency portion of the CDA was instantly challenged on passage, ensuing in the Supreme Court 1997 situation, Reno v.