In Murdock v. Pennsylvania, 319 U.S. 105, 63 S.Ct. 870, 87 L.Ed. 1292 (1943), a religious group attacked the constitutionality of a city ordinance which required it to pay a flat license fee as a condition to conducting its distribution activities. The Supreme Court struck down the ordinance as unconstitutional because the license fee was essentially "a flat tax imposed on the exercise of a privilege granted by the Bill of Rights." Murdock, 319 U.S. at 113, 63 S.Ct. at 875. In referring to the ordinance, the Court stated: The issuance of the permit or license is dependent on the payment of a license tax. And the tax is fixed in amount and unrelated to the scope of the activities of petitioners or to their realized revenues. It is not a nominal fee imposed as a regulatory measure to defray the expenses of policing the activities in question. Id. at 113-14, 63 S.Ct. at 875. The Supreme Court distinguished the state statute it upheld in Cox v. New Hampshire, 312 U.S. 569, 61 S.Ct. 762, 85 L.Ed. 1049 (1941), stating that unlike the statute in Cox, the ordinance challenged in Murdock was not a "state regulation of the streets to protect and insure the safety, comfort, or convenience of the public," and the license fee "was not a nominal one, imposed as a regulatory measure and calculated to defray the expenses of protecting those on the streets and at home against the abuses of solicitors." Id. at 116, 63 S.Ct. at 876.