obligating public sector employees to pay such dues. Commercial speech Commercial speech is speech done on behalf of a company or individual for the purpose of making a profit. Unlike political speech, the Supreme Court does not afford commercial speech full protection under the First Amendment. To effectively distinguish commercial speech from other types of speech for purposes of litigation, the Court uses a list of four indicia: The contents do "no more than propose a commercial transaction". The contents may be characterized as advertisements. The contents reference a specific product. The disseminator is economically motivated to distribute the speech. Alone, each indicium does not compel the conclusion that an instance of speech is commercial; however, "[t]he combination of all these characteristics... provides strong support for... the conclusion that the [speech is] properly characterized as commercial speech." In Valentine v. Chrestensen (1942), the Court upheld a New York City ordinance forbidding the "distribution in the streets of commercial and business advertising matter", ruling the First Amendment protection of free speech did not include commercial speech. In Virginia State Pharmacy Board v. Virginia Citizens Consumer Council (1976), the Court overturned Valentine and ruled that commercial speech was entitled to First Amendment protection: In Ohralik v. Ohio State Bar Association (1978), the Court ruled that commercial speech was not protected by the First Amendment as much as other types of speech: In Central Hudson Gas & Electric Corp. v. Public Service Commission (1980), the Court clarified what analysis was required before the government could justify regulating commercial speech: Is the expression protected by the First Amendment? Lawful? Misleading? Fraud? Is the asserted government interest substantial? Does the regulation directly advance the governmental interest asserted? Is the regulation more extensive than is necessary to serve that interest? Six years later, the U.S. Supreme Court, applying the Central Hudson standards in Posadas de Puerto Rico Associates v. Tourism Company of Puerto Rico (1986), affirmed the Supreme Court of Puerto Rico's conclusion that Puerto Rico's Games of Chance Act of 1948, including the regulations thereunder, was not facially unconstitutional. The lax interpretation of Central Hudson adopted by Posadas was soon restricted under 44 Liquormart, Inc. v. Rhode Island (1996), when the Court invalidated a Rhode Island law prohibiting the publication of liquor prices. School speech In Tinker v. Des Moines Independent Community School District (1969), the Supreme Court extended free speech rights to students in