These legal cases upheld the deletions, and helped to establish the FRC's authority to make decisions needed to effectively regulate broadcasting stations under the Radio Act of 1927.

Although virtually all of the earliest stations operated from fixed locations, a small number were licensed as "portables", that were permitted to regularly change to new sites.

[9] The Federal Radio Commission (FRC) was formed in early 1927, and was charged with bringing stability to the sometimes chaotic state of the AM broadcast band.

As part of its efforts, on April 26, 1927, it released General Order 6, which stated that "Since the exact location of any radio broadcasting transmitter is an essential feature of the license, the Federal Radio Commission, as already announced, will not consider any application for a broadcasting license, except for a very limited period of time, in which the permanent location of the transmitter is not specified."

[10] Subsequently, the FRC's General Order 30, adopted May 10, 1928, specified that all portable stations which had not found permanent homes would have to cease operating by July 1.

[11] Fifteen days later, General Order 34 restated the coming prohibition, noting that there were currently eleven active portable stations, whose licenses would expire as of 3 a.m. July 1, 1928.