In Sable Communications of Cal. v. FCC, the Court examined the constitutionality of a Federal law prohibiting indecent telephone communications. In a two-pronged decision, the Court held that the prohibition of indecency violated the First Amendment by preventing adults from seeing, hearing, or doing that which may be inappropriate for children. The Court correctly used a definitional approach by declining to create intermediate categories of protected speech, thereby maintaining an important safeguard of First Amendment Rights. However, the court ignored the interest of parents in the control and upbringing of their children. In addition, the Court's decision to uphold the prohibition of obscene telephone communications effectively established a national standard of obscenity. The result is that dial-a-porn companies must choose between making their messages acceptable to the least tolerant communities or risking prosecution and possible bankruptcy. 238 footnotes.