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I turned to Jerome Barron's classic article on First Amendment rights of access to the press just as a story appeared in the newspapers. Many political organizations now use a technology called short message service, more colloquially called text messaging, to reach large numbers of people. If you give an organization your cell phone number and sign up for their text messaging program using a "short code," they will send you regular text messages about subjects they think are important. The messages travel through your cell phone carrier's system. NARAL Pro Choice America, an abortion rights group, contacted Verizon requesting permission to send its text messages to Verizon subscribers using a five digit short code, and Verizon refused, saying it violated its policy against "controversial or unsavory text messages."' Verizon said it would block messages coming from NARAL Pro Choice America. As soon as this refusal became public, Verizon backed down, arguing that its employees had misapplied its policy and that of course NARAL was welcome to send messages through its system. But Verizon reiterated its right to block any messages it thought were inappropriate.

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