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Brad Lee Armstrong (argued), Austin, TX, for Plaintiff-Appellant. White Buffalo sought to enjoin UT from excluding its incoming email. On cross-motions for summary judgment, the court granted UT's motion and denied White Buffalo's. Although a court should begin with the expression provided by Congress, it must also “identify the domain expressly pre-empted.” The fact that Congress has expressly preempted certain activity is plain, but the scope of that express preemption is not. We do not organize our discussion around these four propositions (because the appellate briefing renders an alternate organization more desirable), but we discuss each in its appropriate context. If the servers are not, then the First Amendment question is easily resolved-if a server is a private forum, the government may regulate the speech so long as it is viewpoint-neutral. For an explanation as to why only one substantial interest need be satisfied, see part III. By “user efficiency” we mean the ability of UT email account holders to go about their daily business without constantly having to identify and delete unwanted commercial spam.20. This burden is not satisfied by mere speculation or conjecture; rather, a governmental body seeking to sustain a restriction on commercial speech must demonstrate that the harms it recites are real and that its restriction will in fact alleviate them to a material degree. For example, as Updegrove testifies, it would be impossible to filter spam based on whether the originator of the email was a legitimate business. This is no more than a cautionary note, the importance of which has become more plain as a result of our increasing familiarity with litigation involving the Internet. Therefore, the value of that equipment to Compu Serve is diminished even though it is not physically damaged by defendants' conduct.”).


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