broadband to underserved communities. The FCC also addressed the question of whether a municipality was an "entity" under the Telecommunications Act which mandates that "No State or local statute or regulation, or other State or local legal requirement, may prohibit or have the effect of prohibiting the ability of any entity to provide any interstate or intrastate telecommunications service." 47 USC 253(a). The legal question revolved around whether a state could prevent a municipality, as its subordinate government body, from entering the telecommunication market. In the case of Missouri Municipal League v. Nixon, the U.S. Supreme Court concluded that a municipality was not an entity under the Telecommunications Act and that a state could determine what authority its own subordinate jurisdictions had. In 2015, the FCC acted to preempt state laws that restrict municipal broadband providers from extending their service beyond their current boundaries. The FCC grounded its ruling in Section 706 of the Telecommunications Act of 1996, which grants the FCC the authority to encourage the expansion of broadband by using "measures that promote competition in the local telecommunications market, or other regulating methods that remove barriers to infrastructure investment." A challenge to this was won by the states of Tennessee and North Carolina on August 10, 2016 in the Sixth Circuit Court of Appeals. The court ruled that the Telecommunications Act of 1996 did not give the FCC the right to prevent states from prohibiting municipal broadband, on the grounds that the FCC could not reallocate power between a state and its subdivisions. The FCC declined to appeal. In 2021 there were 18 states discouraging or outlawing Municipal Broadband Programs. Many of these laws were passed due to extensive lobbying by large telecom corporations, and corporation-oriented lobbying groups. However, the number of municipal broadband programs is growing. In 2018 there were 108 communities with publicly owned internet and in 2020 there are 560 communities with some form of Municipal Broadband service. Though many states still have laws preventing publicly owned broadband in 2020, the communities that do have municipal broadband believe that it should be "based on needs, capacity, and desire of the community itself." This is due to the virtual monopoly of broadband service held by Comcast and Charter Spectrum, which are known for low value, high prices, and poor customer service. Examples from outside the United States The Dutch capital, Amsterdam has its own municipal broadband