In late 2006, following a decision by the Court of Appeals for the D.C. Circuit in American Council on Education v. FCC, broadband service providers nationwide were suddenly presented with a new and extensive federal mandate. Under the Communications Assistance for Law Enforcement Act of 1994 (CALEA), by May 14, 2007 facilities-based broadband and VoIP service providers were to ensure that their networks are technically capable of providing certain surveillance capabilities to law enforcement, potentially at great expense, or face the prospect of incurring a fine of up to $10,000 per day. Over the intervening months, those service providers who were aware of the new requirements have expended substantial resources simply to determine how and whether to comply, in addition to the direct expense of any technical solution they may be compelled to implement.