Intense tidal heating within Io produces active volcanism on the surface, and its internal structure has long been a subject of debate. A recent reanalysis of the Galileo magnetometer data suggested the presence of a high melt fraction layer with 50~km thickness in the subsurface region of Io. Whether this layer is a magmatic sponge'' with interconnected solid or a rheologically liquid magma ocean’’ would alter the distribution of tidal heating and would also influence the interpretation of various observations. To this end, we explore the steady state of a magmatic sponge and estimate the amount of internal heating necessary to sustain such a layer with a high degree of melting. Our results show that the rate of tidal dissipation within Io is insufficient to sustain a partial melt layer of for a wide range of parameters, suggesting that such a layer would swiftly separate into two phases. Unless melt and/or solid viscosities are at the higher end of the estimated range, a magmatic sponge would be unstable, and thus a high melt fraction layer suggested in Khurana et al. (2011) is likely to be a subsurface magma ocean.

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