Phone services are not publishing. They are also not curating content, promoting speech. The broadcast methods that are available using the phone (robocalls,

Phone services are not publishing. They are also not curating content, promoting speech. The broadcast methods that are available using the phone (robocalls, phone banks) are the same for everyone, and rely only on money and not on algorithmic measures of engage-ability. If a TV station had a call in show where the callers were pre-screened to be slanderous, would that be an example of a publisher or a common carrier? I don't know the answers but it's not so obviously clear cut as running the pipes.