into law by President Bill Clinton by February 1996. Cox/Wyden's section became Section 509 of the Telecommunications Act of 1996 and became law as a new Section 230 of the Communications Act of 1934. The anti-indecency portion of the CDA was immediately challenged on passage, resulting in the Supreme Court 1997 case, Reno v. American Civil Liberties Union, that ruled all of the anti-indecency sections of the CDA were unconstitutional, but left Section 230, among other provisions of the Act, as law. Impact Section 230 has often been called "The 26 words that made the Internet". The passage and subsequent legal history supporting the constitutionality of Section 230 have been considered essential to the growth of the Internet through the early part of the 21st century. Coupled with the Digital Millennium Copyright Act (DMCA) of 1998, Section 230 provides internet service providers safe harbors to operate as intermediaries of content without fear of being liable for that content as long as they take reasonable steps to delete or prevent access to that content. These protections allowed experimental and novel applications in the Internet area without fear of legal ramifications, creating the foundations of modern Internet services such as advanced search engines, social media, video streaming, and cloud computing. NERA Economic Consulting estimated in 2017 that Section 230 and the DMCA, combined, contributed about 425,000 jobs to the U.S. in 2017 and represented a total revenue of annually. Subsequent history Early challengesZeran v. AOL (1997–2008) The first major challenge to Section 230 itself was Zeran v. AOL, a 1997 case decided at the Fourth Circuit. The case involved a person that sued America Online (AOL) for failing to remove, in a timely manner, libelous ads posted by AOL users that inappropriately connected his home phone number to the Oklahoma City bombing. The court found for AOL and upheld the constitutionality of Section 230, stating that Section 230 "creates a federal immunity to any cause of action that would make service providers liable for information originating with a third-party user of the service." The court asserted in its ruling Congress's rationale for Section 230 was to give Internet service providers broad immunity "to remove disincentives for the development and utilization of blocking and filtering technologies that empower parents to restrict their children's access to objectionable or inappropriate online material." In addition, Zeran notes "the amount of information communicated via interactive computer services