[6][12] After getting rid of these time restrictions in 1985, the FCC began to use a system of user identification access codes, in addition to credit cards, to regulate these dial-a-porn services.

The combination of these three regulatory practices were finally supported as being effective enough to protect minors after Carlin Communications, Inc. v. FCC, 837 F.2d 546 (2nd Cir.)

[6] In 1988, Congress amended subsection 223(b) of the Communications Act of 1934 to ban indecent and obscene interstate commercial phone messages, regardless of age.

The federal parties had argued that the only way to prevent children's access to dial-a-porn messages was through the complete ban of their telephone services.

[13][14] The Court said that if the government wants to protect children in this regard, it must do so by technological means, rather than by a total ban on the transmission of these messages.

The court also recognized a real need for governmental interest in shielding children from speech that could be obscene to minors, but not for adults.