Early efforts to control dial-a-porn services failed because existing obscenity law was not adaptable to the modern technology used. A new statute designed specifically to combat dial-a-porn services has been ineffective because the guidelines promulgated thereunder were declared unconstitutional. Meanwhile, dial-a-porn services were making section 1983 (47 U.S.C.) claims against the telephone companies seeking to enforce State-filed tariffs to halt obscene messages. It would be a mistake to allow dial-a-porn services a section 1983 claim against telephone companies, because any incidental inconvenience to a dial-a-porn service's rights to free speech and privacy expression is minimal compared to the compelling governmental interest in the protection of minors. Access and identification code regulation is the most effective, yet least restrictive, alternative for preventing minors from obtaining access to pornographic telephone messages. If dial-a-porn messages are deemed obscene by the courts, they may be disconnected by the telephone companies. If the messages are found to be merely indecent, the messages may not be transmitted to minors. This would require the use of access codes or credit cards to ensure that minors do not have access to the messages. 130 footnotes.