City of East St. Louis, Illinois v. Netflix, Inc.

Dist. Ct. did not err in dismissing action filed by plaintiff-City against defendants-entities providing video-streaming services over Internet, where plaintiff sought declaration directing plaintiffs to become “holders” under Cable and Video Competition Law, 220 ILCS 5/21-191 to 5/21-1601 (CVCL) and to pay five percent of their revenues to plaintiff as fee under CVCL. Statutory scheme requiring said fee applies only to entities providing either cable or video services as defined under CVCL, and defendants did not provide cable services. Moreover, content streamed over Internet is also outside definition of “video services” under CVCL.