 It has been used in "erogenous zoning" cases such as "Renton v. Playtime Theatres, Inc.", 475 U.S. 41 (1986), that limit the concentration or require concentration of certain types of establishments.It has also been used for other types of content-neutral regulation, as well as for content-neutral speech compulsion.Intermediate scrutiny also applies to regulation of commercial speech, as long as the state interests in regulating relate to fair bargaining.