Over several decades states and localities have imposed taxes on a variety of communications services, including telephones, cell phones, and cable and satellite television. Beginning in 2007, state governments began introducing (and in some cases, enacting) legislation to tax digital content delivered over the Internet. As some “deliveries” are like radio and television (delivered for free and paid by advertising); others are subscription deliveries that offer consumers’ access for limited time; and still others are downloads in the nature of a sale, it is not surprising that the state bills impose a variety of taxes, do not always fit well with affected business and often are discriminatory. It can also uncertain whether taxes are being imposed on media service providers, telecommunications companies, or even on both. And a third issue is whether states are authorized to impose taxes on remote sellers such as catalog companies, or in this on case Internet media retailers and services.