Commercial speech is a relatively new member of the family of First Amendment protected speech. The United States Supreme Court first adopted the commercial speech doctrine in 1976 and ever since has had difficulty defining it. In its purest and most simple form, commercial speech is speech proposing a commercial transaction. Unlike content-based regulations, the majority of which must pass strict First Amendment scrutiny, regulations of commercial speech must pass only intermediate scrutiny under the First Amendment. The reason for this inferior level of protection is that commercial speech is low-value speech, meaning the importance of regulating it outweighs any benefit the speech may have to society.