of nearly 20 million, the FCC received only 234 complaints, 217 of which came from the PTC. In October 2003, the FCC decided not to fine NBC because Bono's obscenity was ruled as fleeting and not describing sexual or excretory functions, the FCC's standard for fining a network for indecency. After the PTC filed an Application for Review to the FCC, in March 2004 the FCC decided that the word was indecent by law but still decided not to fine NBC; however, the ruling was to serve as a warning to networks that there would be a "zero tolerance" policy towards obscene language willfully used during the daytime. However, the PTC's complaints about profanity used by presenter Nicole Richie in the December 10, 2003 broadcast of the Billboard Music Awards led the FCC to conclude that the language violated decency law. The PTC began attracting more attention after it filed around 65,000 complaints to the Federal Communications Commission (FCC) about the Super Bowl XXXVIII halftime show, in which one of performer Janet Jackson's nipple shielded breasts, was exposed for 9/16ths of a second. FCC chairman Michael Powell stated that the number of indecency complaints to the FCC had risen from 350 in the years 2000 and 2001, to 14,000 in 2002 and 240,000 in 2003. It was also found that the PTC had generated most of the indecency complaints received by the Federal Communications Commission. In July 2008, the United States Court of Appeals for the Third Circuit voided the fine. After the halftime show, the PTC launched five more FCC complaint drives, starting March 2004 with an episode of Fox's That '70s Show titled "Happy Jack", which revolved around character Eric Forman being caught masturbating. The beginning of the 2004–2005 television season sparked four new campaigns, the first being against NBC's animated series Father of the Pride, stating that it contained a "barrage of sexual innuendo and profanity" while being promoted "from the creators of Shrek", which they felt would potentially attract children to watching the series. That campaign led to over 11,000 email complaints to the FCC. Later, shortly after CBS broadcast the word "fuck" during an airing of Big Brother 5, the PTC took action again, this time claiming that CBS ignored a warning from the Federal Communications Commission (FCC) that there would be zero tolerance toward unbleeped profanity. However, those complaints became moot when Viacom, then-owners