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Telecom: Regulations Student Paper: Powell - California Western
Telecom: Regulations Student Paper: Powell

The V-Chip: Chipping Away at First Amendment Rights

by Andrian Powell


Government regulation of television violence, either through direct action or subtle pressure, is what Justice Brennan feared when he wrote: "It is characteristic of the freedoms of expression in general that they are vulnerable to gravely damaging yet barely visible encroachments." Indeed, a majority of Americans would support government regulation aimed at limiting the amount of violence on the screen, even if that regulation would infringe on the media's constitutional right of free expression. The likely reason for this is that crime is a chief concern of the American public.

Most people also agree that television violence is harmful and "directly contributes the amount of violence in society." A recently released National Television Violence Study appears to substantiate these concerns. The study conducted by four universities concluded that 57 percent of the shows analyzed on broadcast and cable TV contained violence.

Faced with increasing public pressure to act, Congress addressed the problem by incorporating the so-called "V-chip" provisions into the Telecommunications Act of 1996. The "V" in V-chip is for "violence". The provisions require that all new television sets be equipped with a microchip to enable parents to block objectionable programming. Blocking would be automatically triggered by an electronic signal identifying programs deemed objectionable. The Act also encourages the television industry to design voluntary procedures for rating violent programming and coding the material accordingly. If the industry cannot agree internally, a Television Ratings Commission would be formed to rate and control the airing of objectionable programming.

Proponents of V-chip legislation tout it as a "voluntary" system that simply restores parental control of the family television. These proponents claim that the legislation does not impose government censorship and threaten the First Amendment, it instead gives parents more information about television programming and enables them to act on it.

Unfortunately, these proponents could not be more wrong. First, there is nothing voluntary about the proposed rating system. Ratings for television will be imposed by the industry under a government compelled deadline or by a government commission. Second, the legislation is a gateway for massive governmental intrusion into people's lives. Such "unbridled censorship" gives rise to grave First Amendment violations. It invites parents to consider themselves empowered even as they turn over control of their television viewing to bureaucrats in Washington. Therefore, courts should find regulation of violent programming to be incompatible with legal concepts of freedom of speech, and should continue to protect the First Amendment rights of the broadcasters to transmit such information and the rights of the public to receive that information.


The V-chip is a microchip that will be integrated into the circuitry of all newly manufactured televisions. It works similarly to other coding devices, such as closed-captioning, that are now required on most new televisions. Essentially ratings codes will be placed on the programs at the point of transmition. This coded information is transmitted along with the program onto a section of the screen known as the vertical-blanking interval (the black bar that can only be seen when the vertical-hold is off).

The V-chip would translate these codes and block shows that have selected ratings. A parent selects by remote control which program ratings are to be blocked. One system being tested in some parts of Canada rates programs according to violence, language and sexual content and allows parents to choose from among five levels of acceptability. Parents could activate or deactivate the V-chip by punching in a secret identification number, which would prevent interference by children.

The Electronics Industry Association said the chip would add between $5 and $40 to the price of a TV, depending on the model, its computer memory and remote control functions. Although retrofitting could be done, the cost of about $150 for the add-on device would probably limit interest.


The major broadcast television networks have agreed to devise a ratings scheme within the next year that is decodable with the V-chip. Had the networks taken these steps voluntarily, most courts would agree that their First Amendment rights were not infringed. However, the industry was pressured by the new legislation to regulate itself. "We're voluntarily having to comply, " stated the media mogul Ted Turner. "We got the message, it was either going to be done for us or we're going to do it," Turner remarked.

In an analogous situation in 1976, a federal court in California put an end to the "Family Viewing Hour" which the industry had "voluntarily" implemented because of the public outcry against excessive violence on television. Due to congressional hearings and public debates on the issue of the impact of sex and violence on television, the FCC pressured the networks to adopt a system of self regulation. The court found that the FCC exerted improper pressure on the industry which deprived the individual licensees of their right and duty to make independent decisions. The court realized that the steps taken by the networks were not completely voluntary because of the pressure the FCC had placed on them, and held that "the Family Viewing Hour was an improper government intrusion into the broadcasters First Amendment rights." Therefore, the government's insistence on voluntary industry action for a ratings systems may be counter-productive because the courts will find that the industry did not take the actions voluntarily.


A. State and Federal Courts

Most state and federal courts agree that television violence is a protected class of speech under the First Amendment. In Zamora v. CBS, a fifteen-year-old boy sued CBS, NBC, and ABC for damages, claiming that he became "involuntarily addicted to and 'completely subliminally intoxicated' by the extensive viewing of television violence." Zamora maintained that this desensitization to violent behavior led him to murder his 83 -year-old neighbor. The court refused to impose liability on the broadcasters because of the negative impact that such an imposition would have on the exercise of their First Amendment rights.

Similarly, in DeFilippo v. NBC, the Supreme Court of Rhode Island held that the First Amendment barred suit against the broadcaster when the plaintiff 's thirteen-year-old son hanged himself after watching a stuntman "hang" Johnny Carson (who survived) on The Tonight Show. Allowing plaintiffs to recover in such actions would have a chilling effect on the First Amendment, and would eventually lead broadcasters to self-censor their programs. This would "deprive both broadcasters and viewers of freedom and choice, for 'above all else, the First Amendment means that government has no power to restrict expression because of its message, its ideas, its subject matter or its content.' "

A California court, in Olivia N. v. NBC, reacted similarly to a suit charging NBC with negligence for its broadcast of the film Born Innocent. A group of girls attacked and forcibly "artificially raped" the nine-year-old plaintiff with a bottle, after viewing and discussing a scene in the film where four girls artificially rape another girl in a shower room using the handle of a plunger. In rejecting the plaintiff's negligence theory asserted against the television broadcaster, the court addressed the effects that imposing liability would have on the networks. The fear of damage awards to plaintiffs would lead to self-censorship that "would dampen the vigor and limit the variety of public debate." Such results undermine the First Amendment by significantly limiting the selection of controversial subjects and materials to be televised. 

B. The Supreme Court

The Supreme Court has not had an opportunity to examine television violence in a First Amendment context, however, the Court has found other content-based regulations to be "presumptively invalid." One such case involved a licensing ordinance for the City of Dallas, Texas. Under the Dallas ordinance, a film had to be reviewed by a Motion Picture Classification Board and receive a rating. Theatres were required to obtain a special license to show films with a "not suitable" rating. The Supreme Court struck down the ordinance as a violation of the First Amendment. In doing so, the Court cited a host of other decisions in which similar content-based ratings systems had been struck down as unconstitutional. The Court was not impressed with the city's argument that its licensing system was consistent with the First Amendment because it employed "classification rather than direct suppression." The Court said, "The vast wasteland that some have described in reference to another medium might be a virtual paradise" compared to a world in which films are judged according to a government ratings system.

Not all content-based regulations, however, are treated the same for First Amendment purposes. The Court has historically afforded lesser degrees of scrutiny to a few specific categories of speech, and obscenity is clearly outside the First Amendments protection. In Chaplinsky v. New Hampshire, the Court offered this rationale for classifying some forms of speech as unprotected: "Such utterances are no essential part of any exposition of ideas, and are of such slight social value as a step to truth that any benefit that may be derived from them is clearly outweighed by the social interest in order and morality."

In Chaplinsky, the Court held that "the lewd and obscene, the profane, the libelous, and the insulting or 'fighting' words" have less value under the First Amendment and, consequently, are afforded somewhat reduced constitutional protection. The Supreme Court later added commercial speech and child pornography to the categories of speech entitled to lesser protection.

There can be no serious contention that televised violence falls within any existing category of low-value speech. Fighting words are remarks uttered in a face-to-face confrontation that are inherently likely to provoke the listener to immediate violence. Libel requires a false statement of fact. Child pornography is material depicting sexual performances by children. Commercial speech is expression that proposes a commercial transaction. And obscenity is limited to a subcategory of sexually explicit material. Therefore, violent programming does not, without more, fall into any of the existing low-value categories.

C. Public Policy Rationale

It is not inconceivable that the Court may hold media violence to be a new class of low-value speech. The Court has offered at least two public policy reasons for holding some forms of speech to a lesser degree of protection. In Paris Adult Theatre I v. Slaton, the Court asserted that suppression of obscene material was justified to protect "public safety." Although the Court admitted that no scientific data conclusively demonstrated that exposure to obscene materials promotes antisocial behavior, "the legislature of Georgia could quite reasonably determine that such a connection does or might exist." In addition to its concern for "safety," the Court has suggested that regulation is permissible if it furthers the state's interest in maintaining a "decent society." This interest, says the Court, justifies the regulation of material that offends the "sensibilities of unwilling recipients."

The court has been reluctant to extend these two rationales, societal harm and sensibilities of the listener, to other forms of speech. For example, the Supreme Court held that Nazis denied a permit to march were entitled to immediate appellate review of the decision. Likewise, a federal district court held a University of Michigan "hate speech" regulation unconstitutional under the First Amendment, as overbroad and impermissibly vague. Similarly, federal courts have prohibited the government from preventing merchants from using trade names that may be offensive to significant segments of the community, such as "Crazy Horse" for an alcoholic beverage or "Sambo's" for a restaurant. Courts have even rejected the argument that pornography should be regulated because it harms society by perpetuating the subordination of women which leads to gender inequality and violence. In American Booksellers Ass'n v. Hudnut, the U.S. Court of Appeals for the Eighth Circuit rejected this argument in affirming the invalidation of an Indianapolis ordinance that defined pornography to include nonobscene material that depicted women in a sexually subordinate way. Although acknowledging that pornography has "deleterious social effects," the court nevertheless concluded that the First Amendment protects such speech, no matter how insidious. "Any other answer leaves the government in control of all of the institutions of culture, the great censor and director of which thoughts are good for us."

The reluctance of courts to carve out new exceptions using these rationales makes it unlikely that they will be willing to do so for television violence. In fact, there have been some clues that violent depictions will remain protected speech. In Winters v. New York, for example, the Supreme Court offered this statement regarding the protected nature of violent speech: "Though we can see nothing of any possible value to society in these magazines, they are as much entitled to the protection of free speech as the best of literature."

The Court has made it clear that the First Amendment is designed to protect "all ideas having even the slightest redeeming social importance -- unorthodox ideas, controversial ideas, even ideas hateful to the prevailing climate of opinion." Thus, to create a new class of low-value speech anytime the speech is hurtful or damaging to the listener, would undermine the entire First Amendment.


If television violence cannot be equated with low-value speech, perhaps it can be regulated because it is speech delivered over the airwaves. Since the Radio Act of 1912, the federal government has played a role in regulating the electromagnetic spectrum, and the Supreme Court has adopted a different First Amendment standard for speech transmitted on this regulated medium: "We have long recognized that each medium of expression presents special First Amendment problems. And of all forms of communication, it is broadcasting that has received the most limited First Amendment protection."

A. Scarcity of the Electromagnetic Spectrum

In National Broadcasting Co. v. United States, the Supreme Court justified governmental control of broadcast licenses based on the theory of spectrum scarcity. The First Amendment implications of spectrum scarcity was later explained in Red Lion Broadcasting, Inc v. FCC. The Court rationalized limited First Amendment protection for broadcasting because electromagnetic spectrum is a limited resource. The court agreed that the government must assume control of the spectrum, in trust for the public, to prevent competitors broadcasting on the same frequency, causing interference or drowning each other out. The court also agreed that the government may therefore require its licensees to broadcast in the public interest. Because "it is the right of viewers and listeners, not the right of the broadcasters, which is paramount," Congress may regulate broadcasters' speech under more lenient standards than would apply to regulations of speech of the other media. Based on this concept of public interest, the FCC in 1949 promulgated the "Fairness Doctrine". The doctrine imposed on every broadcaster "certain obligations to afford reasonable opportunity for the discussion of conflicting views on issues of public importance."

The Supreme Court questioned the continued vitality of the scarcity rationale in FCC v. League of Women Voters. The Court, however, refused to reconsider its approach "without some signal from Congress or the FCC that technological developments have advanced so far that some revision of the system of broadcast regulation may be required."

The FCC accepted the Court's invitation in 1985, concluding that scarcity no longer existed and that the fairness doctrine did indeed impede rather than enhance speech. As the result of later litigation, the FCC held in 1987 that the fairness doctrine both no longer served the public interest because of the growth in the number of broadcast outlets since Red Lion and was unconstitutional because it led broadcasters to censor their coverage of controversial issues.

There can be little doubt that scarcity of the broadcast spectrum is not an accurate technological description of the spectrum today. Although the radio spectrum may have appeared limited when the Court decided Red Lion, today the nation enjoys a proliferation of broadcast stations. Lack of broadcast spectrum fails to justify such different First Amendment treatment accorded broadcast media in light of modern technological advances.

B. Pervasiveness of the Medium

In 1978, in FCC v. Pacifica Foundation, the Court offered two additional rationales for granting limited First Amendment protection to broadcasting. One of the defendant's New York radio stations broadcast humorist George Carlin's "Filthy Words" monologue at two o'clock in the afternoon. Upon receiving a complaint from a listener, the FCC concluded that the language used by Carlin was not "obscene", but was "indecent" and prohibited by statute. The D.C. Circuit reversed, but the Supreme Court reversed the circuit court and affirmed the FCC order. One explanation offered by the Court why regulation of broadcast indecency was permitted without First Amendment concerns, was that "the broadcast media have established a uniquely pervasive presence in the lives of all Americans."

The Pacifica Court believed that television and radio communication is "pervasive" because the listener cannot get away from it: "To say that one may avoid further offense by turning off the radio when he hears indecent language is like saying that the remedy for an assault is to run away after the first blow." But the Court has been quite willing in other situations to instruct people to "turn away" when they encounter speech they find offensive. In Cohen v. California, the Court held that those exposed to Paul Cohen's jacket, bearing the phrase "Fuck the Draft," could "effectively avoid further bombardment of their sensibilities simply by averting their eyes." In Erznoznik v. City of Jacksonville, the Court placed an identical burden on the viewer by sustaining a challenge to a city ordinance prohibiting drive-in movie theaters with screens visible from the streets from showing movies containing nudity.

The Pacifica Court distinguished Cohen and Erznoznik on the grounds that neither took place within the privacy of the home. In Consolidated Edison Co. v. Public Service Commission, however, the Court held that an order of the New York Public Service Commission prohibiting the inclusion in monthly electric bills of materials that discussed controversial issues of public policy violated the First Amendment. As in Pacifica, this material entered the home, yet the Court found its regulation impermissible: "Even if a short exposure to Consolidated Edison's views may offend the sensibilities of some consumers, the ability of government 'to shut off discourse solely to protect others from hearing it is dependent upon a showing that substantial privacy interests are being invaded in an essentially intolerable manner.'"

The pervasiveness rationale certainly does not distinguish broadcast from other types of media such as print. The onslaught of catalogues and junk mail, and now junk telephone and e-mail, are more intrusive than a controllable television set or radio. Therefore the pervasiveness theory does not justify disparate treatment of the broadcast media in violation of the First Amendment.

C. Protection of Children

The second justification the Pacifica Court offered for regulation of broadcast indecency is that broadcasting is "uniquely accessible to children, even those too young to read." Because protection of children has always been a compelling state interest, regulation of speech directed at children is constitutionally permissible in certain circumstances. Despite this interest, the case law does not support a lesser First Amendment protection for broad regulation of televised violence.

Generally the state has two compelling interests with regard to children. The government has an interest in helping parents supervise their children and an interest in shielding minors from physical and psychological abuse. Competing against these interests are the First Amendment rights of minors and of those adults whose access to speech is restricted due to the protection of children. As to the children's rights, the Court has stated: "Speech that is neither obscene as to youths nor subject to some other legitimate proscription cannot be suppressed solely to protect the young from ideas or images that a legislative body thinks unsuitable for them." Although Pacifica may have limited this language to cases in which very young children are involved, courts still maintain the principle that "restrictions on First Amendment rights, even when imposed in the best interest of children, must still be narrowly tailored and no more burdensome than necessary to advance the protective goal."

The First Amendment right of adults must also be considered. In Butler v. Michigan, the Court struck down a conviction under a state law banning the dissemination of books "found to have a potentially deleterious influence upon youths." The Court concluded that the impermissible effect of the statute was "to reduce the adult population ... to reading only what is fit for children." Similarly in Interstate Circuit, Inc. v. Dallas, in finding a state statute requiring theaters to obtain a special license to show "unsuitable movies" as unconstitutional, the Court was unswayed by the city's argument that the ordinance was "adopted for the salutary purpose of protecting children." The Court said that the statute would cause theatre owners to shy away from any films that would receive an "unsuitable" rating, so that they would "contract to show only the totally inane."

The Pacifica Court stated, however, that adults who would not be able to hear the Carlin monologue could simply purchase recordings or go to theaters and nightclubs to hear such words. Not only does this violate the right of the adult population to receive communications, it also forces speakers to restrict their speech to ensure that it does not reach young ears. Such a rule means that newspapers and home-delivered magazines would have no right to distribute to adults material unfit for children.

Therefore, a lesser First Amendment standard of review does not apply simply because a regulation seeks to protect children. The First Amendment interests of parent and child are equally important regardless of the proposed purpose of the restriction. Depictions of violence on television thus are fully protected speech under the First Amendment, and any effort to regulate or inhibit them would be subjected to a strict scrutiny standard.


Two other legal principles draw into question certain efforts to regulate television violence: vagueness and overbreadth. A law is unconstitutionally vague when it does not inform people of common intelligence precisely what conduct is forbidden so they "must necessarily guess at its meaning and differ as to its application." This standard is even narrower in the First Amendment context, where greater specificity is required in order to prevent a chilling effect on speech. A law regulating speech will be deemed overbroad if it sweeps within its ambit a substantial amount of protected speech along with what it may legitimately regulate.

A law regulating speech is overbroad when it proscribes conduct which is protected by the guarantees of free speech. A primary rationale for employing the overbreadth doctrine is that overinclusive laws have a chilling effect on free speech. When a statute overreaches and prohibits some protected speech, a person may be unsure whether his conduct falls under that prohibition. Thus, even if his speech is protected, he might be intimidated and not exercise his right to speak at all. Moreover, overbroad statutes are susceptible to selective enforcement by the authorities.

With respect to the V-chip legislation's attempt to regulate violent programming, the difficulties in defining "violence" will almost certainly raise vagueness and overbreadth concerns. Although the same criticism could apply to the FCC's efforts to regulate "indecency," a generic standard for regulating broadcast indecency has been upheld because indecency has been the source of regulation since the 1927 Radio Act, removing from its meaning the shroud of vagueness that would surround efforts to regulate other forms of speech defined generically. The problems encountered in defining violence are apparent in the Eighth Circuit's invalidation on vagueness grounds of a Missouri statute regulating dissemination of violent materials to minors. "Without a definition of 'violence,' the statute lacks any 'narrowly drawn, reasonable and definite standard' identifying the expression that is subject to the statute's restriction."

Further, courts would likely find an overbreadth problem if violence is simplistically rated on one level without applying different standards for different types of violence. If the definition of violence encompasses too much activity that viewers do not consider violent, the rating system will lose credibility and ultimately be ignored. If most programs receive a violence rating, the system will become meaningless. Furthermore, the "use of overbreadth analysis reflects the conclusion that the possible harm to society from allowing unprotected speech to go unpunished is outweighed by the possibility that protected speech will be muted." Thus, programmers will be so concerned with avoiding violence ratings that they will refrain from exercising their rights to freedom of expression.

The V-chip legislation attempts to avoid the definitional problem by delegating the authority to the industry or to the FCC. Still, when it comes to implementation, those same definitional problems will undoubtedly trigger the vagueness and overbreadth arguments.


The government may regulate the content of constitutionally protected speech only in order to promote a compelling state interest, and then only if it adopts the least restrictive means to further that interest. Because televised violence is constitutionally protected speech, any regulation aimed at restricting its flow into American homes must first pass the Supreme Court's strict scrutiny standard. The Court's varied articulations of strict scrutiny indicate a two prong analysis: a "compelling interest" component and a "narrowly tailored" one. To determine the constitutionality of regulating television violence, each element must be satisfied.

A. Compelling Interest

In applying the "compelling interest" prong, the state bears the burden to advance the interest(s) that the challenged regulation is purported to serve. Whether one is more "compelling" is simply a value judgment to be made by the court. The Court has recognized that the state has a compelling interest in "protecting the physical and psychological well-being of minors." Crime prevention is also a compelling interest. Congress has cited as its purpose for the V-chip bill, the protection and welfare of children, and at least implicitly refers to the protection of society from violence. Because both of these interests are compelling, V-chip legislation is not likely to fail the "compelling interest" portion of the strict scrutiny test.

B. Narrowly Tailored

The "narrowly tailored" prong of the strict scrutiny test should prove more fatal to efforts to regulate violent programming. To be narrowly tailored, the regulation must be "precisely drawn" and it must impose no greater infringement upon the affected speech than is necessary. Restrictive regulation passes constitutional muster only if it does not restrict more speech than is necessary to achieve its end. "Where constitutional rights are at stake, important ends do not sustain mismatched means." The social science research does not conclusively establish that a reduction in children's exposure to televised violence will further any of the state's articulated interests. Laboratory and field experiments have shown little more than was found two decades ago by the Surgeon General: television violence may lead to some aggression in children, but it tends to affect only children predisposed to aggression and even then only in some environmental contexts. Correlational studies have failed to provide a causal link between violent television and societal violence. Because courts may not defer to legislative findings when First Amendment rights are at stake, any reasonable judicial review will find the government's interest in protecting children and preventing crime are not clearly served by regulating televised violence. In other words, the means simply do not match the ends.


Aside from the First Amendment issues, technological advances should also cause concern about the V-chip. The cable industry has begun to develop systems capable of delivering 500 channels. Direct broadcast satellite already brings 150 channels directly into American homes. Telephone companies are poised to begin sending video and audio material across telephone lines. A host of other technologies will offer even more alternatives such as master antenna television and multipoint distribution service. The sheer volume of information that will flow into the home makes it hard to imagine how every bit and byte could be pre-evaluated for violent content. Not only would regulation be virtually impossible because of the amount of information, but the amount of information also may make regulation unnecessary. If consumers value violence-free programming enough, there is no reason to believe that broadcasters will not respond by providing several sources of programming to meet this demand.

As an alternative to a government implanted V-chip, the public should be better informed about emerging technologies that empower consumers to make intelligent programming decisions for their families. One such system is called TV Guide On Screen. It is an interactive on-screen programming guide which provides viewers with full program information, editorial coverage, and other features of TV Guide. It also features two-way viewer participation and a variety of menu options. It contains a "lock-out" feature which allows parents to block out specific programs or entire channels. Unlike a hardware solution such as the "V-Chip," TV Guide On Screen can be instantly and inexpensively upgraded. Moreover, the system does not encroach upon broadcasters' freedom of speech rights because families subscribe to TV Guide On Screen by choice. Thus, the government does not become "the conscience of the American people and assume the role of censor."

Other new technologies include: (1) the Direct Broadcast Satellite system, which is menu-driven, provides on-screen information to viewers, and employs parental control features with a password; (2) the "Yes-Chip," which relies on speaker identification, voice recognition, and on-screen displays to facilitate program choices by either parent; and (3) Video Freedom, which allows viewers to blur selected audio and visual elements that they may find objectionable. All these alternatives are preferable to government-mandated lock-out-systems in television sets. Furthermore, the First Amendment is not implicated because the censorship and control is in the hands of the parents who choose to install and use the systems, rather than a government agency.


Contrary to the characterizations of its congressional sponsors, the V-chip is not a voluntary solution to the issue of televised violence. Instead, this legislation which is intended to restrict televised violence, will ultimately restrict freedom of speech and expression. The American people must realize that they own the airwaves. Censorship of these airwaves restricts their rights to send and receive messages and ideas. Justice Brennan feared that society's dominant culture could force its values on the minority through censorship, and those fears are distressingly valid today.

What television needs is not censorship, but a greater awareness and sensitivity on the part of broadcasters and viewers alike. We must turn to alternative choices, such as education and new technology, rather than let the government intrude on the dissemination of ideas. Ultimately, parents are responsible for their children, and must be the ultimate decision makers on what is suitable for their children to watch on television. Any proposal to empower parents should be informational rather than instructional. It should provide parents with the information they need to exert control over content coming into their households, without preaching to them which values are acceptable.


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Video Software Dealers Ass'n v. Webster, 968 F.2d 684 (8th Cir. 1992).

Winters v. New Tork, 333 U.S. 507 (1948).

Writers Guild v. FCC, 423 F. Supp. 1064 (C.D. Cal. 1976), vacated and remanded on jurisdictional grounds sub nom. Writers Guild v. ABC, 609 F.2nd 355 (9th Cir. 1979), cert denied, 449 U.S. 824 (1980).

Zamora v. CBS, 480 F.Supp. 199 (S.D. Fla 1979).



Andrew Barrett, Reflections on Television Violence and Regulating New Technologies, 4-SPG Kan. J.L. & Pub. Pol'y 105, (1995).

Robert Corne-Revere, Television Violence and the Limits of Voluntarism, 12 Yale J. on Reg. 187, (1995).

Chuck Ross, Raising Static Over V-chip; Experts Fear Advertiser Exodus, Flight to Cable, Advertising Age, Mar. 4, 1996, 1996 WL 7537646.

Joanne Ingrassia, Canada Eyes U.S. as it Tests V-chip, Electronic Media, March 4, 1996, 1996 WL 7534646.

Robert Corne-Revere, Vchipping Away at the Constitution, The Washington Post, Jul. 28, 1995, 1995 WL 9254385.