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Explanations for issue framing by movements and movement opponents often externalize opportunities for issue framing. In this paper, I draw attention to the endogenous processes through which opportunities for issue framing can unfold. I do this through a case study analysis of counter-movement framing of network neutrality policy in the United States, from 2005 to 2015. Drawing primarily from an original dataset of Congressional hearings concerning network neutrality policy, I argue that network neutrality opponents activated new framing opportunities through non-discursive activity in institutional venues. Specifically, I show how the ‘regulatory authority’ frame that came to characterize later discussions of network neutrality in Congress became available only after counter-movement opponents challenged early regulatory rules in court, thereby legitimizing – partly through the court’s proceedings, and partly by instigating a response from the regulator – an alternative conceptualization of network neutrality policy as a threat to constitutional principles of governance. In doing so, I articulate a view of framing opportunities as (at times) latent within institutional contexts, dependent on non-discursive activity by movement and counter-movement actors to be brought into play.