The fine, the largest for a US television network to date, was imposed in September as a result of the halftime performance of Jackson, who appeared alongside Justine Timberlake.
In a 78-page letter sent to the Federal Communications Commission last week, CBS is arguing that the exposure was as much as a shock to it as it was to everyone else. It has described the fine as "illogical" and based on the idea that it was complicit in planning the incident.
"No one at the network knew, or had reason to suspect, that the halftime show would end with a glimpse of nudity," the letter said.
The incident sparked outrage among US viewers, generating more than 500,000 complaints.
CBS was quick to apologise and heap the blame on Jackson, but the US regulator paid scant attention to the network's apology and fined 20 CBS-owned TV stations $27,500 each.
Timberlake claimed after the event that it was caused by a problem with Jackson's outfit -- Jackson simply described the breast-baring faux pas as an "accident".
The FCC is studying the letter from CBS and it is believed that the battle is likely to end up in court.
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