sentiments on all subjects, being responsible for the abuse of this right." In its historical development of "commercial speech", the United States Supreme Court has also extended this right to commercial entities.
On example of this extended right in the case of Bigelow v. Virginia, 421 U.S. 809 (1976) where an editor of a Virginia newspaper was convicted in violation of a Virginia statute, which declared that the sale or circulation of any publication to encourage or promote obtaining an abortion was considered a misdemeanor. The Supreme Court held that:
Speech is not stripped of First Amendment protection merely because it appears in the form of a paid commercial advertisement, and the fact that the advertisement in question had commercial aspect or reflected the advertiser's commercial interest did not negate all First Amendment guarantees. Id., at 809.
This was one of the earliest cases where the Court recognized "commercial speech."
Another example was in the case, the Virginia State Board of Pharmacy v. Virginia Citizens Consumer Council, Inc., 425 U.S. 748 (1976), when consumers of prescription drugs brought suit against the Virginia State Board of Pharmacy and its individual members, challenging the validity of a Virginia Statute declaring it unprofessional conduct for a licensed pharmacist to advertise the price of prescription drugs. The Supreme Court held that, "Commercial speech, like other varieties is protectedà[and] some form of commercial speech regulation are surely permissible" Id., at 770. Therefore, the United States Supreme Court has, in different opinions, held that, "commercial speech" is a recognized form of speech. The Court also held, however, that, "Untrue speech, commercial or otherwise, has never been protected for its own sake" Id., at 771. Specifically, in the case of Virginia State Board of Pharmacy, it was made clear that "commercial speech" is not protected if it is used to deceive, li...