Honestly asking, my memory of new events from that era is somewhat hazy.
This may have been revised extensively in the Telecommunications Act of 1996 [4] and with subsequent policy changes around treatment of "telecommunications services", "information services" and "common carriers" but the point remains: Title II has a long history.
[1] https://en.wikipedia.org/wiki/Net_neutrality_in_the_United_S...
[2] https://en.wikipedia.org/wiki/Communications_Act_of_1934#Str...
[3] https://transition.fcc.gov/Reports/1934new.pdf, pp35-136
[4] https://en.wikipedia.org/wiki/Telecommunications_Act_of_1996...