paid consultants who not only view voter microtargeting as highly effective but also have assigned it a crucial role in determining the outcome of the past three presidential campaigns. . (16) The political consulting firm Cambridge Analytica reportedly used a database of 220,000,000 Americans, including thousands of unique data points on each individual and inferred personality trait analysis, to conduct psychological operations changing people’s minds not through persuasion but through informational dominance , a set of techniques that includes rumor, disinformation and fake news . Cambridge Analytica reportedly worked in 44 United States elections in 2014 and another 50 in 2016, including on behalf of 2 major Presidential campaigns. (17) In Sorrell v. IMS Health Inc., the Supreme Court invalidated a Vermont State law regarding restrictions on the use of personal information as violating the First Amendment. The court held that the government’s prohibition disfavor[ed] … speech with a particular content, namely marketing, and disfavor[ed] specific speakers, namely pharmaceutical manufacturers because it interfered with the manufacturers’ attempts to persuade recipients to use their products. Psychological targeting techniques seek to manipulate, not to persuade. (18) In Citizens United v. FEC, the Supreme Court invalidated the Federal Election Campaign Act’s prohibition on corporate independent expenditures on the grounds that the First Amendment does not allow political speech restrictions based on a speaker’s corporate identity . Allowing individuals to control the use of their own personal information in the context of an election does not restrict the political speech of any person based on their identity. (19) In Buckley v. Valeo, the Supreme Court invalidated the Federal Election Campaign Act’s expenditure limitations, finding that they impose direct and substantial restraints on the quantity of political speech . Allowing individuals to control the use of their own personal information in the context of