The to start with main obstacle to Section 230 itself was Zeran v. AOL, a 1997 situation made a decision at the Fourth Circuit. Cox/Wyden's part grew to become Section 509 of the Telecommunications Act of 1996 and grew to become legislation as a new Section 230 of the Communications Act of 1934. The anti-indecency portion of the CDA was quickly challenged on passage, resulting in the Supreme Court 1997 situation, Reno v.