ABSTRACT
But by 1996, that vehicle had reached a crossroads. Telephone companies had assaulted regulation that confined them to serve as pure vehicles with a barrage of lawsuits claiming a First Amendment right to provide content as well.3 Telephone companies chaffed at the restricted role of transporter and moved to embrace a dual function as both content supplier and carrier.4 To effect this shift in status, telephone companies claimed they were being unconstitutionally deprived of their right to speak by regulations the government claimed merely constrained the economic structure of the communications industry.5
