1
Judge blocks Utah's VPN age-verification rule
Possible
Resolves by End of 2026
Discussed by: Aylo's legal team and constitutional law scholars who view the extraterritoriality argument as strong
Barlow grants Aylo's preliminary injunction, pausing Utah's 2026 law while the lawsuit proceeds. Aylo keeps blocking Utah users. A ruling for Aylo on the dormant Commerce Clause would signal that state laws punishing VPN-using out-of-state users reach too far.
2
Court upholds the law; Aylo appeals
Possible
Resolves by End of 2026
Discussed by: Utah's Attorney General's Office, which argues compliance is feasible and not unduly burdensome
Barlow denies the injunction, finding the state's interest in shielding minors outweighs the compliance burden. Utah's rule takes effect for Aylo, and the company appeals to the 10th Circuit, which would then evaluate the novel VPN provision.
3
Rulemaking leads to settlement
Uncertain
Resolves by Q2 2027
Discussed by: The joint stipulation, which lets Aylo participate in rulemaking without liability
The Division of Consumer Protection finalizes its administrative rule, expected in October 2026. Aylo's counsel has signaled openness to participating. If the rule addresses key concerns, the company may drop the lawsuit with the law left in place.
4
Utah Appeals the Injunction to the 10th Circuit
Possible
Resolves by Q2 2027
Discussed by: Utah Attorney General's Office, which has argued the law is workable
Utah asks the 10th Circuit to lift the injunction, arguing Judge Barlow misread the statute. The VPN provision stays blocked while the appeal runs. The circuit would be the first appellate court to weigh a state law targeting VPN use around age checks.
5
Barlow Rules on the Law's Constitutionality
Uncertain
Resolves by End of 2027
Discussed by: Both parties, who continue litigating after the preliminary injunction
Judge Barlow decides whether the actual-location provision violates the Commerce Clause or the First Amendment. His injunction order noted the statute 'says nothing about reasonableness in geolocation efforts.' A final ruling could come in 2027.
6
Legislature Amends Law; Aylo Drops Lawsuit
Uncertain
Resolves by Mar 15, 2027
Discussed by: Joint motion from Aylo and Utah Attorney General, which stated the parties anticipate the legislature may amend S.B. 73
Utah's 2027 session rewrites the VPN provision, adding a reasonableness standard. If the amendment addresses Aylo's constitutional objections, the company could drop the lawsuit. The injunction is the backdrop for negotiations.
