As the majority notes, the Supreme Court has stated that "the solicitation of charitable contributions is protected speech." Maj. Op. at 1176

—holding that a request for charity or gifts, whether "on the street or door to door," is protected First Amendment speech

—the Supreme Court struck down an ordinance prohibiting solicitation by charitable organizations that did not use at least seventy-five percent of their revenues for charitable purposes.

Charitable solicitation indisputably involves speech interests "that are within the protection of the First Amendment."

Solicitation "is characteristically intertwined with informative and perhaps persuasive speech seeking support for particular causes or for particular views on economic, political, or social issues," so that "without solicitation the flow of such information and advocacy would likely cease."

Given a case or controversy, a litigant whose own activities are unprotected may nevertheless challenge a statute by showing that it substantially abridges the First Amendment rights of other parties not before the court

—holding that "charitable appeals for funds, on the street or door to door, involve a variety of speech interests—communication of information, the dissemination and propagation of views and ideas, and the advocacy of causes—that are within the protection of the First Amendment

The government elaborates that the Court has distinguished commercial speech from, for example, charitable solicitation, because "charitable solicitation does more than inform private economic decisions and is not primarily concerned with providing information about the characteristics and costs of goods and services

The Village may serve its legitimate interests, but it must do so by narrowly drawn regulations designed to serve those interests without unnecessarily interfering with First Amendment freedoms

The Court held that "[t] he Village's legitimate interest in preventing fraud can be better served by measures less intrusive than a direct prohibition of solicitation. Fraudulent misrepresentations can be prohibited and penal laws used to punish such conduct directly."

[CITATION] Illinois v. Telemarketing Associates, Inc.