The initially main challenge to Section 230 by itself was Zeran v. AOL, a 1997 situation resolved at the Fourth Circuit. Cox/Wyden's section turned Section 509 of the Telecommunications Act of 1996 and turned legislation as a new Section 230 of the Communications Act of 1934. The anti-indecency part of the CDA was promptly challenged on passage, resulting in the Supreme Court 1997 situation, Reno v.