View source for Mozilla Corp. v. FCC

{{Short description|2019 American court case}}
{{Infobox U.S. Courts of Appeals case
| CourtName = United States Court of Appeals for the District of Columbia Circuit
| CourtSeal = Seal of the Court of Appeals for the District of Columbia.png
| Membership = Stephen F. Williams, Patricia Millett, Robert L. Wilkins
| Litigants = Mozilla v. FCC
| ArgueDate = February 1
| ArgueYear = 2019
| DecideDate = October 1
| DecideYear = 2019
| FullName = Mozilla Corporation v. Federal Communications Commission and United States of America
| USVol = 
| USPage = 
| Citation = 940 F. 3d 1
| Prior = 
| Subsequent = 
| Holding = The FCC has the authority to reclassify Internet services under the Communications Act of 1934, but does not have the authority to restrict state or local laws regulating Internet services.
| PerCuriam = yes
| Concurrence = Millett
| Concurrence2 = Wilkins
| Concurrence/Dissent = Williams
| LawsApplied = 
}}
{{Net neutrality}}

'''''Mozilla Corp. v. FCC''''', 940 F. 3d 1 (D.C. Cir., 2019) was a ruling the United States Court of Appeals for the District of Columbia Circuit in 2019 related to net neutrality in the United States. The case centered on the Federal Communications Commission (FCC)'s decision in 2017 to rollback its prior 2015 Open Internet Order, reclassifying Internet services as an information service rather than as a [[Common carrier|common carrier]], deregulating principles of net neutrality that had been put in place with the 2015 order. The proposed rollback had been publicly criticized during the open period of discussion, and following the FCC's issuing of the rollback, several states and Internet companies sued the FCC. These cases were consolidated into the one led by the [[Company:Mozilla Corporation|Mozilla Corporation]].<ref name=":0">''Mozilla Corp. v. Federal Communications Commission'', [https://scholar.google.com/scholar_case?case=14265735163164690369&q=Mozilla+v.+FCC&hl=en&as_sdt=6,39 940 F. 3d 1] (D.C. Cir., 2019).</ref>

The Appeals Court ruled in favor of the FCC in October 2019, relying on the Supreme Court decision of ''National Cable & Telecommunications Ass'n v. Brand X Internet Services'' (2005) that the FCC has such authority to reclassify Internet services, and thus allowed the rollback. However, the Court ruled against the FCC in attempting to block state- and local-level laws that regulated the Internet, enabling states to pass net neutrality legislation.<ref name=":0" />

==Background==
Net neutrality in the United States has been of concern since the Internet became open to public use through Internet service providers (ISPs). [[Net neutrality]] broadly encompasses the idea that all data traffic on the Internet should be treated equal, counter to past and planned actions of ISPs to offered tiered service plans that block or throttle access to selected sites at lower payment tiers, among other provisions. Within the United States, proponents of net neutrality, which typically includes Democrats and large technology companies, believe it is necessary to prevent ISPs from blocking access to Internet services or to throttle the connection to these services as to maintain an open flow of information across the Internet without discrimination. Opponents of net neutrality, principally Republicans and ISPs, argue that the ability to offer tiered rates of service would help promote competition in providing Internet service across America, and enforced net neutrality regulations would stifle growth.<ref name="wired guide">{{cite magazine | url = https://www.wired.com/story/guide-net-neutrality/ | title = The WIRED Guide to Net Neutrality | first = Klint | last= Finley | date = May 9, 2018 | accessdate = October 4, 2019 | magazine = Wired }}</ref>

A central facet of the debate around net neutrality is how ISPs are classified under the Communications Act of 1934. Under this act, they may either treated as "information service" under Title I of the Act, or as a "[[Common carrier|common carrier]] service" under Title II. Common carrier classification under Title II would mean that the FCC, which is granted authority to oversee communication services in the United States, could apply regulations to ISPs, which would include enforcing the principles of net neutrality. But under Title I, the FCC would not have significant authority to regulate ISPs.<ref name="wired guide"/> The FCC's authority to classify ISPs in this matter was upheld in the Supreme Court case ''National Cable & Telecommunications Ass'n v. Brand X Internet Services'' in 2005, based principle on the ''Chevron'' deference for the judiciary to allow federal agencies' interpretations of ambiguous Congressional language. With ''Brand X''{{'}}s ruling left in place the FCC's decision to classified cable-based ISPs as information services under Title I.<ref name="ars decision">{{cite web | url = https://arstechnica.com/tech-policy/2019/10/why-ajit-pais-unhinged-net-neutrality-repeal-was-upheld-by-judges/ | title = Why Ajit Pai's "unhinged" net neutrality repeal was upheld by judges | first = Jon | last= Brodkin | date = October 2, 2019 | accessdate = October 4, 2019 | work = [[Ars Technica]] }}</ref>

==Case background==
The FCC in the early 2010s, while under the [[Biography:Barack Obama|Barack Obama]] administration, were favorable to implementing net neutrality positions. The first FCC Commissioner in Obama's term, Julius Genachowski, was a strong proponent of net neutrality.<ref name="NYTnn1">{{cite news |url= https://www.nytimes.com/2009/01/14/us/politics/14fcc.html |title=Julius Genachowski to Be Nominee for F.C.C. Chairman |work={{wipe|The New York Times}} |date=January 13, 2009 | accessdate =October 4, 2019 | first=Stephen |last=Labaton}}</ref> Tom Wheeler, appointed as the new FCC Commissioner in 2013, had stated he was for an open Internet but favored the notion of "fast lanes" for some traffic,<ref>{{cite web | archiveurl= https://web.archive.org/web/20141126140827/http://money.cnn.com/2014/04/23/technology/open-internet/index.html?iid=EL | archivedate=November 26, 2014 | url = https://money.cnn.com/2014/04/23/technology/open-internet/index.html?iid=EL | title= Regulators pave way for Internet "fast lane" with net neutrality rules | first = James | last = O'Toole | date =  April 23, 2014 }}</ref>  but eventually agreed to full net neutrality goals as to maintain the goals of an open Internet.<ref>{{cite web | url = https://arstechnica.com/tech-policy/2017/12/tom-wheeler-slams-ajit-pais-plan-to-kill-net-neutrality-rules/ | title = Tom Wheeler slams Ajit Pai's plan to kill net neutrality rules | first = Jon | last = Brodkin | date = December 6, 2017 | accessdate = October 4, 2019 | work = [[Ars Technica]] }}</ref> The FCC introduced the [[FCC Open Internet Order 2010]] that enshrined principles of net neutrality.<ref>{{cite magazine |url=https://www.wired.com/epicenter/2010/12/fcc-order/ |magazine=Wired |first=Sam |last=Gustin |title=FCC Passes Compromise Net Neutrality Rules |date=December 21, 2010 | accessdate = October 4, 2019 }}</ref> The order was challenged by ISPs, and in 2014, the DC Appeals Court ruled in ''[[Verizon Communications Inc. v. FCC (2014)|Verizon Communications Inc. v. FCC]]'' that the FCC did not have the authority to set net neutrality requirements on ISPs unless they were classified as a common carrier.<ref>{{cite web |last=Brodkin |first=Jon |title=Net neutrality is half-dead: Court strikes down FCC's anti-blocking rule |url=https://arstechnica.com/tech-policy/2014/01/net-neutrality-is-half-dead-court-strikes-down-fccs-anti-blocking-rules/|access-date=January 14, 2014 | date = October 4, 2019 }}</ref> This led the FCC to issue a new Open Internet Order in 2015 that not only continued to enshrine net neutrality principles but also classified ISPs as Title II common carriers.<ref>{{cite web |last=Reisinger |first=Don |title=Net neutrality rules get published – let the lawsuits begin |url=http://www.cnet.com/news/fccs-net-neutrality-rules-hit-federal-register-lawsuit-underway/ |date=April 13, 2015 |work=CNET |access-date=April 13, 2015}}</ref> Again, ISPs sued the FCC over this. In 2016, the DC District Court ruled in ''United States Telecom Ass'n v. FCC'' in favor of the FCC and upholding the reclassification of ISPs and the neutrality rules.<ref>{{cite web | url = https://www.nytimes.com/2016/06/15/technology/net-neutrality-fcc-appeals-court-ruling.html | title = Court Backs Rules Treating Internet as Utility, Not Luxury | first=  Cecelia | last = Kang | date = June 15, 2016 | accessdate = October 26, 2018 | work = {{wipe|The New York Times}} }}</ref>

With Donald Trump becoming president in 2016, Ajit Pai, a current member of the FCC was elevated to the new FCC Commissioner. Pai was a strong critic of the FCC having oversight of net neutrality prior to this position, believing that the FCC should allow ISPs to self-regulate, and that if there was to be regulation on net neutrality, it needed to come from Congress.<ref name=nyt.testimony>{{Cite news|url=https://www.nytimes.com/2017/12/14/technology/net-neutrality-repeal-vote.html |title=F.C.C. Backs Opening Net Neutrality Rules for Debate |last=Wyatt |first=Edward |date=May 15, 2014|work=New York Times|access-date=December 14, 2017}}</ref><ref>{{cite web |url=https://www.npr.org/sections/alltechconsidered/2017/05/05/526916610/fcc-chief-net-neutrality-rules-treating-internet-as-utility-stifle-growth |title=FCC Chief Makes Case For Tackling Net Neutrality Violations 'After The Fact' |last=Selyukh |first=Alina, David Greene |date=May 5, 2017 |website=NPR|access-date=May 26, 2017}}</ref> With Pai as Commissioner, and with Republican-appointed members outnumbering the Democrat-appointed ones 3–2, Pai led the FCC to propose a rollback of the 2015 Open Internet Order. By May 2017, the FCC voted to proceed the process of rolling back the 2015 Order by issuing a public notice of the FCC's intent of the rule change, titled "Restoring Internet Freedom". In addition to the rollback, the proposed rule would prevent states and local governments from passing legislation on net neutrality.<ref>{{cite web |url=https://money.cnn.com/2017/05/18/technology/fcc-net-neutrality-vote/index.html |title=FCC votes to move forward with net neutrality rollback |last=Fiegerman |first=Seth |date=May 18, 2017 |website=CNN Tech|access-date=May 26, 2017}}</ref>

The proposed changed drew heavy criticism from proponents of net neutrality, with several organized activism events created to draw the public's attention to this. During the public commenting period, running from May to August 2017, the FCC received more than 21 million comments related to the change.<ref>{{cite web | url = https://www.vox.com/2017/8/30/16223210/net-neutrality-fcc-21-million-record-comments-duplicates-suspicious-data | title = Many of the FCC's record-breaking 21 million net neutrality comments are duplicates — or come from suspicious sources | first1 = Tony | last1= Romm | first2= Rani | last2= Molla | date= August 30, 2017 | accessdate = October 4, 2019 | work = [[Recode]]}}</ref> Analysis of the comments following their release after the public period found a near majority of these opposed to the rule change, even after accounting for potential fraud that had been discovered.<ref>{{cite web | url = https://www.nytimes.com/2018/10/16/technology/net-neutrality-inquiry-comments.html | title = New York Attorney General Expands Inquiry Into Net Neutrality Comments | first =Nichalos | last = Confessore | date = October 16, 2018 | accessdate = October 17, 2018 | work = {{wipe|The New York Times}} }}</ref><ref>{{cite web | url = https://www.buzzfeednews.com/article/kevincollier/feds-investigation-net-neutrality-comments | title = Millions Of Comments About The FCC's Net Neutrality Rules Were Fake. Now The Feds Are Investigating. | first1=  Kevin | last1 = Collier | first2= Jeremy | last2= Singer-Vine | date = December 8, 2018 | accessdate = December 8, 2018 | work = Buzzfeed News }}</ref><ref>{{cite web | url = https://thehill.com/policy/technology/419846-fcc-chairman-acknowledges-russia-interfered-in-net-neutrality-public | title = FCC chairman acknowledges Russia interfered in net neutrality public comments | first = Emily | last =Brimbaum | date = December 5, 2018 | accessdate = December 5, 2018 | work = The Hill }}</ref>  Despite the public stance on the rule change, the FCC voted on December 14, 2017, to enforce the rollback.<ref name='ArsTech20180105'>{{cite web | last = Brodkin | first = Jon | date = January 4, 2018 | title = FCC releases final net neutrality repeal order, three weeks after vote: With repeal officially published, FCC will soon face lawsuits. | work = [[Ars Technica]] | url = https://arstechnica.com/tech-policy/2018/01/fcc-releases-final-net-neutrality-repeal-order-three-weeks-after-vote/ | accessdate= January 5, 2018}}</ref>

==Appeals Court==
Immediately after the FCC vote in December, several states issued statements of the intent to sue the FCC over this change.<ref>{{cite news |last1=Griswold |first1=Alison |title=The first lawsuit to save net neutrality was announced minutes after the FCC voted to repeal it |url=https://qz.com/1157178/us-state-attorneys-general-are-already-suing-to-save-net-neutrality-from-the-fcc/ |work=Quartz |accessdate=December 14, 2017 |date=December 14, 2017}}</ref> Once the rule change was published in the Federal Register in February 2018, twenty-two states and several other state and local agencies joined in the complaint lodged by [[Company:Mozilla Corporation|Mozilla Corporation]] and [[Company:Vimeo|Vimeo]] against the FCC, to be heard in the DC Appeals Court.<ref name="Shepherdson">{{cite news | url = https://www.reuters.com/article/us-usa-internet/states-refile-lawsuits-to-block-repeal-of-u-s-net-neutrality-idUSKCN1G62F8 | title = States refile lawsuits to block repeal of U.S. net neutrality | first = David | last =Shepherdson | date = February 22, 2018 | accessdate = October 12, 2018 | work = {{wipe|Reuters}} }}</ref> The suit asserted that the FCC had been "arbitrary and capricious" in handling net neutrality, and disregarded "critical record evidence on industry practices and harm to consumers and businesses".<ref name="Shepherdson"/>

The case was heard before the DC Appeals Court on February 1, 2019, before Senior Circuit Judge Stephen F. Williams and Circuit Judges Patricia Millett and Robert L. Wilkins.<ref>{{cite web | url = https://www.npr.org/2019/02/01/690609162/net-neutrality-goes-back-to-court | title = Net Neutrality Goes Back To Court | first = Matthew S. | last = Schwartz | date = February 1, 2019 | accessdate = October 4, 2019 |  publisher = NPR }}</ref> Mozilla and the states argued on points that the FCC, in making the rollback rule, failed to analyze current market conditions correctly, account for public safety, erred in how it classified ISPs as an information service, and asserted that the FCC did not have authority to block states from passing net neutrality laws.<ref name="verge orals"/> The FCC argued that the former net neutrality rules had harmed broadband investment, and that consumers would be protected by required transparency reports from ISPs. Several ISPs and trade groups representing them also joined the FCC to argue that there was evidence to suggest that net neutrality rules were required to prevent consumers from being harmed by aggressive throttling and blocking.<ref name="verge orals"/>

A major point brought up by the judges was related to the 2018 California wildfires,<ref name="verge orals">{{cite web | url = https://www.theverge.com/2019/2/1/18207062/fcc-net-neutrality-lawsuit-hearing-court | title = What we learned from net neutrality's big day in court | first=  Colin | last = Lecher | date = February 1, 2019 | accessdate= October 4, 2019 | work = [[The Verge]] }}</ref> in which it had been discovered that first responders' communications, operating through Verizon, were being throttled due to going over a certain bandwidth capacity, which significantly reduced the effectiveness of the responders to react to the changing fire conditions.<ref>{{cite web | url = https://arstechnica.com/tech-policy/2018/08/verizon-throttled-fire-departments-unlimited-data-during-calif-wildfire/ | title = Verizon throttled fire department's "unlimited" data during Calif. wildfire | first = Jon | last =Brodkin | date = August 21, 2018 | accessdate = October 4, 2019 | publisher = [[Ars Technica]] }}</ref>

==Concurrent actions==
While the case was pending in the Appeals Court, California passed the California Internet Consumer Protection and Net Neutrality Act of 2018 in September 2018. The law was written to enforce net neutrality principles for ISPs operating in California. The law was passed despite the fact that the FCC order passed earlier asserted states could not set net neutrality regulations themselves.<ref>{{cite web | url = https://www.theverge.com/2018/10/3/17933804/net-neutrality-california-bill-broadband-isp-sb822 | title=  Broadband industry groups sue California over net neutrality bill | first = Makena | last = Kelly | date = October 3, 2018 | accessdate = October 3, 2018 | work = [[The Verge]] }}</ref> Shortly after passage, the FCC sued California for this law on the basis of the 2017 rule; the FCC was joined by several ISPs and agencies representing them in suing the state.<ref>{{cite web | url = https://www.nytimes.com/2018/09/30/technology/net-neutrality-california.html | title = Justice Department Sues to Stop California Net Neutrality Law | first = Cecilia | last = Kang | date = September 30, 2018 | accessdate = October 3, 2018 | work = {{wipe|The New York Times}} }}</ref> Both sides agreed to hold off any further legislation or enforcement of the law pending the decision of the ''Mozilla'' case.<ref name="verge ca law 2018">{{cite web | url = https://www.theverge.com/2018/10/26/18029226/net-neutrality-fcc-california-law-ajit-pai-scott-wiener | title = California strikes deal with FCC to delay state net neutrality law | first = Makena | last = Kelly | date = October 26, 2018 | accessdate = October 26, 2018 | work = [[The Verge]] }}</ref>

==Decision==
The DC Appeals Court issued its decision on October 1, 2019. In the ''per curiam'' decision, the Court voted to uphold the FCC's rollback of the 2015 Open Internet Order, ruling that the agency had been affirmed to have that authority through the prior ''Brand X'' case and was not at liberty to challenge the Supreme Court ruling there.<ref name="ars decision"/><ref name="verge decision">{{cite web | url = https://www.theverge.com/2019/10/4/20898779/fcc-net-neutrality-court-of-appeals-decision-ruling | title = The Court Allowed The FCC To Kill Net Neutrality Because Washing Machines Can't Make Phone Calls | first=  Nilay | last = Patel | date = October 4, 2019 | accessdate = October 4, 2019 | work = [[The Verge]] }}</ref> The decision affirmed several of the points made by the FCC in relation to the potential harm to ISPs by imposing net neutrality, and agreeing that ISPs are more common to information services than common carriers.<ref name="verge decision"/>

However, on the matter of limiting state and local-level enforcement of net neutrality, the Court ruled that the FCC had overstepped its bounds, and reversed that part of the rule. The opinion denied the claim that the FCC had implied authority on this matter, and stated "If Congress wanted Title I to vest the Commission with some form of Dormant-Commerce-Clause-like power to negate States' statutory (and sovereign) authority just by washing its hands of its own regulatory authority, Congress could have said so."<ref name="verge decision"/> In addition, the Court ordered the FCC to review its rule change on the effect for public safety as related to the California wildfire incident, and the impact on low-income telecommunications services.<ref>{{cite web | url = https://www.theverge.com/2019/10/1/20893342/fcc-net-neutrality-repeal-dc-appeals-court-ruling-state-law-preemption | title = The FCC can repeal net neutrality, but it can't block state laws, says court | first = Adi | last = Robertson | date = October 1, 2019 | accessdate=  October 1, 2019 | work = [[The Verge]] }}</ref><ref>{{cite news | url = https://www.washingtonpost.com/technology/2019/10/01/appeals-court-upholds-trump-administrations-cancelling-net-neutrality-rules | title = Appeals court ruling upholds FCC's canceling of net neutrality rules | first=Tony | last= Romm | date = October 1, 2019 | accessdate = October 4, 2019 | newspaper = {{wipe|The Washington Post}} }}</ref><ref>{{cite web | url = https://www.wsj.com/articles/fcc-rollback-of-net-neutrality-rules-is-partly-upheld-by-appeals-court-11569942446 | title= FCC Rollback of Net Neutrality Rules Is Partly Upheld by Appeals Court | first1 = Brent | last1 = Kendall |  first2 = John D. | last2= McKinnon | date = October 1, 2019 | accessdate = October 4, 2019 | work = {{wipe|The Wall Street Journal}} }}</ref>

Each of the three judges wrote an additional opinion. Both Circuit Judges Millett and Wilkens wrote in concurrence of the ''per curiam'' decision, while Senior Circuit Judge Williams wrote in part concurrence and part in dissent. All three reflected on the change of the Internet structure since ''Brand X'' was decided and pointing out that today, ISPs are better classified as information services than common carriers. At the time of ''Brand X'', the Supreme Court had relied on the existing of core technologies like caching at the ISP level and the Domain Name Service to justify that ISPs are information services. In this ruling, the judges noted that now, Internet services are defined by information that consumers can access, and as such, ISPs should be able to offer those consumers who want faster access to that information the capabilities to offer tiered service without regulation.<ref name="ars decision"/><ref name="verge decision"/>

==Subsequent actions==
Because of the Appeals Court decision that only partially upheld the FCC's ruling, either side may seek appeals with the Supreme Court. Parties that supported the plaintiffs, including the Computer & Communications Industry Association, other trade groups, and some of the states that joined with them sought an ''[[Social:En banc|en banc]]'' hearing from the full Appeals Court, but this request was denied in February 2020.<ref>{{cite web | url = https://www.reuters.com/article/us-usa-internet/us-appeals-court-will-not-reconsider-net-neutrality-repeal-ruling-idUSKBN20032K | title = U.S. appeals court will not reconsider net neutrality repeal ruling | first = David | last =Shepardson | date = February 6, 2020 | accessdate = February 6, 2020 | publisher = {{wipe|Reuters}} }}</ref>

While the decision was seen as a short-term defeat for net neutrality proponents, the decision clearing the way for state and local regulation was seen as net positive. While California's net neutrality law is still barred from enforcement until the FCC's case against the state is complete, state lawmakers saw the decision as a victory since they expect the courts to clear the state of any wrongdoing in passing the legislation.<ref>{{cite web | url = https://www.latimes.com/business/story/2019-10-03/fcc-net-neutrality-ruling-california | title = Upholding FCC's repeal of net neutrality rules, court opens door for California to enforce its own | first=  Suhauna | last =  Hussain | date = October 3, 2019 | accessdate = October 4, 2019 | work = The Los Angeles Times }}</ref> Four other states have passed or have pending legislation to enforce net neutrality at the state level while an additional 33 other states along with the District of Columbia have proposed bills favoring net neutrality. However, it is expected that there will be ongoing legal challenges from ISPs for these state bills that may limit their enforcement.<ref>{{cite web | url = https://www.cnet.com/news/net-neutrality-battle-lives-on-what-you-need-to-know-after-the-appeals-court-decision/ | title = The net neutrality battle lives on: What you need to know after the appeals court decision | first= Marguerite | last = Reardon | date = October 3, 2019 | accessdate = October 4, 2019 | work = CNet }}</ref>

Another potential route would be for Congress to pass legislation overriding the FCC's decision to classify ISPs as common carriers or otherwise enforce net neutrality. Some lawmakers have attempted to pass such laws, but none has succeeded. There are also concerns that in haste to pass legislation, Congress may support poorly-thought out legislation, or legislation that also contains "trojan horse" clauses favorable to special interests. Mark Stanley of Demand Progress suggested that ISPs and telecomm groups may seek to lobby Congress to pass a weaker form of net neutrality to minimally satisfy its proponents but still would be beneficial to ISPs.<ref>{{cite web | url = https://www.dailydot.com/layer8/net-neutrality-court-decision-bad-bills/ | title = Net neutrality advocates say to remain wary of 'bad legislation' in wake of court's decision | first=  Andrew | last= Wyrich  |date = October 3, 2019 | accessdate = October 4, 2019 | work = [[Company:The Daily Dot|The Daily Dot]] }}</ref>

The FCC issued another public commenting period from February to March 2020 to gain input on the factors of public safety, reduced infrastructure spending, and impact on the Lifeline program as identified in the Appeals Court ruling.<ref>{{cite web | url = https://www.engadget.com/2020/02/21/fcc-public-comment-net-neutrality/ | title = FCC forced to ask for public feedback on net neutrality repeal | first = Daniel  |last = Cooper | date = February 21, 2020 | accessdate = February 21, 2020 | work = [[Software:Engadget|Engadget]] }}</ref> Following the public comment period, the FCC voted again in October 2020 on the same 3–2 lines to uphold their prior decision, with Pai, in a separate post, stating that based on the public comments he was "confident that the regulatory framework we set forth in the Restoring Internet Freedom Order appropriately and adequately addresses each issue."<ref>{{cite web | url = https://thehill.com/policy/technology/522947-fcc-reaffirms-order-rolling-back-net-neutrality-regulations | title = FCC reaffirms order rolling back net neutrality regulations | first = Rebecca | last= Klar | date = October 27, 2020 | accessdate = November 1, 2020 | work = The Hill }}</ref>

==References==
{{reflist}}

==Further reading==
*{{cite web | last=Chin | first=Caitlin | title=In the net neutrality debate, what might follow Mozilla v. FCC? | website=Brookings | date=October 7, 2019 | url=https://www.brookings.edu/blog/techtank/2019/10/07/in-the-net-neutrality-debate-what-might-follow-mozilla-v-fcc/ }}

==External links==
* {{Federal Register|83|7852}} - "Restoring Internet Freedom" FCC Order, published February 22, 2018
* [https://docs.fcc.gov/public/attachments/DOC-360042A1.pdf DC Circuit decision]

[[Category:Net neutrality]]

{{Sourceattribution|Mozilla Corp. v. FCC}}