posted on its services, while Prodigy had employed a team of moderators to validate content. Both companies faced legal challenges related to content posted by their users. In Cubby, Inc. v. CompuServe Inc., CompuServe was found not be at fault as, by its stance as allowing all content to go unmoderated, it was a distributor and thus not liable for libelous content posted by users. However, in Stratton Oakmont, Inc. v. Prodigy Services Co., the court concluded that because Prodigy had taken an editorial role with regard to customer content, it was a publisher and was legally responsible for libel committed by its customers. Service providers made their Congresspersons aware of these cases, believing that if followed by other courts across the nation, the cases would stifle the growth of the Internet. United States Representative Christopher Cox (R-CA) had read an article about the two cases and felt the decisions were backwards. "It struck me that if that rule was going to take hold then the internet would become the Wild West and nobody would have any incentive to keep the internet civil," Cox stated. At the time, Congress was preparing the Communications Decency Act (CDA), part of the omnibus Telecommunications Act of 1996, which was designed to make knowingly sending indecent or obscene material to minors a criminal offense. A version of the CDA had passed through the Senate pushed by Senator J. James Exon (D-NE). People in a grassroots effort in the tech industry reacted to try to convince the House of Representatives to challenge Exon's bill. Based on the Stratton Oakmont decision, Congress recognized that requiring service providers to block indecent content would make them be treated as publishers in the context of the First Amendment, and thus would make them become liable for other content such as libel, not set out in the existing CDA. Cox and fellow Representative Ron Wyden (D-OR) wrote the House bill's section 509, titled the Internet Freedom and Family Empowerment Act, designed to override the decision from Stratton Oakmont, so that a service provider could moderate content as necessary and would not have to act as a wholly neutral conduit. The new provision was added to the text of the proposed statute while the CDA was in conference within the House. The overall Telecommunications Act, with both Exon's CDA and Cox/Wyden's provision, passed both Houses by near-unanimous votes and was signed