Intra-day variability (IDV) of active galactic nuclei (AGN) has been detected from gamma-ray energies to radio wavelengths. At high energies, such variability appears to be intrinsic to the sources themselves. However, at radio wavelengths, brightness temperatures as high as 1018 to 1021 K are encountered if the IDV is intrinsic to the source. We discuss here the accumulating evidence showing that, at radio wavelengths where the highest brightness temperatures are encountered, interstellar scintillation (ISS) is the principal mechanism causing IDV. While ISS reduces the implied brightness temperatures, they still remain uncomfortably high.