sed pertained to constitutional interests"(Boedecker and Morgan, 2). There were limitations placed on time, place, and manner and the court could also enforce rules that dealt with false, deceptive, or misleading advertising. Five years later, the Central Hudson Gas & Electric Corp. v. Public Service Commission (1980) developed a four-part breakdown for commercial speech. Throughout the courts case it used these four steps, "(1) Determine whether the expression is protected by the First Amendment, that is, does it involve lawful activity and not mislead the audience? (2) Does the government have a substantial interest to be achieved by restricting the speech? (3) Does the regulation directly advance the government's interest? (4) Is the regulation more extensive then necessary to achieve that interest?" (Boedecker and Morgan, 1) this was a significant move in the direction for commercial speech. "The currently used Central Hudson test creates an artificial distinction between 'commercial' and 'noncommercial' speech" (Coach, 3). The issues involved in Central Hudson represents a change in direction in terms of deciding what degree of protection to grant commercial statements. It includes a judgement about the importance of regulating the subject matter or activity in question and therefor withdrew some of the protection granted upon commercial speech in the previous year. In summary, more types of communication are moving toward the commercial speech category, which means more first amendment protection for commercial speech. Therefor, there are two problems that marketers face when it come to commercial speech, identifying commercial speech and applying it to the commercial speech standard.
             In broad terms, is the speech actually commercial? This is one of the simplest issues throughout a commercial speech case. So if the answer is "yes" and the speech is found to ...