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On September 24, 2026, U.S. District Judge David Barlow preliminarily blocked Utah from enforcing the actual-location provision in its online age-verification law. The court read that provision to require covered websites to identify a user’s physical location even when a VPN or proxy hides it—a level of certainty the court said is not presently possible. The order does not block Utah’s entire age-verification law or decide the case permanently.
What did the Utah court block?
In Aylo Freesites Ltd. v. Utah Division of Consumer Protection, Judge David Barlow enjoined Utah Code § 78B-3-1002(3), the actual-location provision added by SB 73. The court’s September 24, 2026 order is a preliminary injunction, not a final judgment on the constitutional merits. Read the court’s order.
The provision treats a person as accessing a website from Utah if they are physically in the state, regardless of whether they use a VPN, proxy, or another means to disguise their location. The earlier law separately requires certain commercial entities that publish material harmful to minors online to use reasonable age-verification methods.
Why did the court call the location requirement impossible?
A website generally sees the public IP address from which a connection arrives. A VPN routes traffic through an intermediary server, so the site may see the server’s IP address rather than one tied to the user’s physical location. A proxy can also obscure where a connection originates. As a result, an IP-based location lookup can point to a place other than the user’s actual location.
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Utah argued that websites could supplement IP geolocation with VPN detection and other signals, including a device’s time zone and region, language or locale settings, currency preferences, browser language headers, and account history. Those clues can help estimate location, but the record recognized that they are imperfect; they do not establish a person’s physical location with certainty.
The court focused on the difference between the statute’s wording and the state’s proposed interpretation. The law expressly describes age-verification methods as “reasonable,” but the court found no comparable reasonable-efforts qualification in the actual-location provision. It rejected Utah’s attempt to read such a standard into that text. The order says the provision requires covered entities to “geolocate its website users with perfection to avoid liability” and states, “It is undisputed that geolocation perfection is not presently possible.”
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VPNs can be used to obscure location, but they also have legitimate uses, such as securing communications on public networks, reducing data harvesting, and circumventing censorship. The order’s central point was not that location signals are useless; it was that the provision, as the court read it, exposed a website to liability without allowing for the limits of those signals.
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The injunction is limited to the actual-location provision. Judge Barlow expressly declined to enjoin the separate age-verification requirement, which Aylo did not challenge in this motion. The ruling therefore does not strike down all of SB 73, invalidate every age-verification law, or resolve the constitutional questions that remain in the lawsuit.
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The Electronic Frontier Foundation (EFF) also says Aylo did not challenge a separate provision restricting covered websites from sharing information about VPNs. EFF argues that the location rule could affect users outside Utah because platforms would face pressure to locate every user perfectly or verify all users to avoid liability. That is EFF’s explanation of the rule’s broader implications, not the scope of the court’s injunction. EFF’s account of the ruling.
KUER’s contemporaneous report likewise describes the injunction as covering the VPN-related location update while leaving the broader age-verification law in place pending a decision on constitutionality. Read KUER’s report.
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What happens next?
The order is preliminary, so the case can continue and the court may address the merits later. The injunction prevents enforcement of § 78B-3-1002(3) pending further court action; it should not be mistaken for a permanent ruling on every part of Utah’s online age-verification framework.
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