Last month, the U.S. Federal District Court for the District of Nebraska granted Vonage Holdings, Inc.’s (“Vonage”) motion for summary judgment in a case that challenged the Nebraska Public Service Commission’s (“PSC”) rules requiring VoIP providers to support the state’s Universal Service Fund (“USF”). The court’s decision means that interconnected VoIP providers are no longer required to remit contributions to the Nebraska Fund and may have broader implications, particularly in states like New Mexico and Kansas, which had in recent months either proposed or adopted rules similar to the Nebraska rules struck down by the Court.