 The CDA, among other things, made it illegal to publish, distribute or disseminate "indecent" material on the Internet.The "indecency" standard had long been imposed on over-the-air broadcasters, both radio and television, by the Federal Communications Commission; it was most famously defined and upheld in "Federal Communications Commission v. Pacifica Foundation", a case determining that George Carlin's famous Seven Dirty Words monologue was indecent.Boe was lead counsel in "Shea v. Reno", filed in federal court in New York at about the same time as the ACLU filed their challenge to the same statute in Philadelphia.