be profound and serious.  Any missteps will injure our country gravely and diminish our position 
as the leading world economy. 
77
Nor has the Commission shown, as it must, that Internet advertising transactions, or 
transactions involving Internet and Web services, are uniquely susceptible to fraud.  
Accordingly, the selective regulation of Internet advertising services would plainly violate 
fundamental guarantees of equal protection under the Fifth Amendment.
78
   
B. 
The Internet and Web Services Exception Violates The First Amendment. 
The FTC's proposal to selectively target commercial speech about Web and Internet 
services also is repugnant to the First Amendment.  Even when strict scrutiny is not applied to 
such regulations under an equal protection analysis, disparate regulations of commercial speech 
and speakers still are subject to searching review under at least the intermediate level of 
constitutional scrutiny under the First Amendment.
79
  Under this commercial speech test, known 
as the  
Central Hudson
 test,  a governmental restriction on truthful commercial speech about 
lawful activity will be upheld only if:  (1) the asserted government interest is substantial; (2) the 
regulation directly advances the governmental interest asserted; and (3) the regulation is not 
more extensive than is necessary to serve that interest.
80
                                                 
77
Commissioner Orson Swindle, 
Should Policymakers Apply a Depression Era Tax System to the Economy of the 
21st Century?
, Address at the Policy Perspectives on the Taxation of Cyberspace Conference on E Commerce (May 
12, 2000), 
at
 http://www.ftc.gov/speeches/swindle/ denver000512.htm.  Commissioner Swindle also noted that 
 [u]nwarranted taxes and regulation at a time when the technology is still rapidly evolving threaten to lock in or 
limit the Internet to specific technologies and modes of service that fall far short of its likely potential.   
Id.
78
See
, 
e.g.
, 
Burkhart Advertising Inc. v. City of Auburn
, 786 F. Supp. 721, 732 (N.D. Ind 1991) (invalidating statute 
on equal protection grounds where the defendants could not show how billboards advertising commercial goods and 
services were any more distracting or unattractive than billboards promoting noncommercial services and 
messages). 
79
See
, 
e.g.
, 
Lorillard Tobacco Co. v. Reilly
, 121 S. Ct. 2404, 2421 (2001
); Greater New Orleans Broadcasting 
Ass'n v. United States
, 527 U.S. 173, 184 (1999); 
Central Hudson
, 447 U.S. at 562 63 (1980).  The Supreme Court 
recently has acknowledged a movement among several Justices toward applying strict scrutiny to all government 
restrictions on commercial speech, but the Court has yet to  break [such] new ground.  
Lorillard
, 121 S. Ct. at 2421.   
80
Central Hudson, 
447 U.S. at 566. 
26




  

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