The 1st significant problem to Section 230 alone was Zeran v. AOL, a 1997 circumstance made the decision at the Fourth Circuit. Cox/Wyden's part 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 part of the CDA was quickly challenged on passage, ensuing in the Supreme Court 1997 circumstance, Reno v.