"The steady advances in video technology, and corresponding shifts in consumer viewing habits, have eradicated any justification that may once have existed for subjecting broadcasters to less First Amendment protection than other media," Fox said.
The filing is in response to the FCC's announcement in April that it is considering relaxing its policies when it comes to enforcing content regulations on broadcast television and radio.
Specifically, the agency is pondering whether to shift the focus of its enforcement efforts to egregious cases as opposed to issuing fines for the occasional inadvertent fleeting expletive or flash of nudity.
Fox said the FCC's rules are "stuck in a bygone era" and are unfair to broadcasters because cable and online outlets do not face the same regulations.
"The FCC should affirm that it has no right to deny broadcasters the same First Amendment protections enjoyed by every other medium of communication," Fox said. The only time the FCC should even consider weighing in on a content issue, Fox added, is "if the subject matter of the broadcast content constitutes the equivalent of a highly graphic and sustained verbal or visual shock treatment."
CBS echoed Fox's arguments. In its comments, the network said the FCC shouldn't be worried that relaxing its enforcement will make "broadcast television some sort of red-light district."
But not everyone wants the FCC to step back from enforcement. The Parents Television Council ripped Fox for its comments and cited the network's animated sitcom "Family Guy" as a prime example of a show that goes too far.
"The American people (those without armies of lobbyists) are concerned about the volume of indecent material on TV that is targeting their children and grandchildren. The FCC and Congress must not ignore their voices," said PTC President Tim Winter.
Follow Joe Flint on Twitter @JBFlint.