The very first main problem to Section 230 by itself was Zeran v. AOL, a 1997 circumstance decided at the Fourth Circuit. Cox/Wyden's section became Section 509 of the Telecommunications Act of 1996 and turned regulation as a new Section 230 of the Communications Act of 1934. The anti-indecency part of the CDA was right away challenged on passage, resulting in the Supreme Court 1997 scenario, Reno v.