Pre 2015, the FCC was enforcing NN through other means. In late 2014, a court case declared the method they were enforcing didn't fall under the scope of their

Pre 2015, the FCC was enforcing NN through other means. In late 2014, a court case declared the method they were enforcing didn't fall under the scope of their powers, but strongly suggested, while noting that the ISPs could and would be a danger to the internet if left to their own devices, that they had other means to enact the same regulations. The other means was Title II classification.