(M. Lepoutre, “Can ‘More Speech’ Counter Ignorant Speech?” (2019), 16 J. Ethics & Owen M. Fiss, The Irony of Free Speech and Liberalism Divided” (1998), 43 McGill L.J. 445, at pp. 464-65; C. F. Zwibel, “Reconciling Rights: The Whatcott Case as Missed Opportunity” (2013), 63 S.C.L.R. (2d) 313, at pp. 332-33). The theory is that dissenting voices can “out-compete more pernicious speech” in the marketplace of ideas (C. Forcese and K. Roach, “Criminalizing Terrorist Babble: Canada’s Dubious New Terrorist Speech Crime” (2015), 53 Alta. L. Rev. 35, at p. 47), showing that, “though some citizens may hold despicable ideas, the weight of public opinion runs against them” (Horwitz, at p. 464). In American First Amendment jurisprudence, this concept is called “counterspeech” (Whitney v. California, 274 U.S. 357 (1927), per Brandeis J., concurring; United States v. Alvarez, 567 U.S. 709 (2012), per Kennedy J. (plurality opinion)). [81] In s. 2(b) jurisprudence, the idea of counter-speech inheres in the recognition that the open exchange of ideas is a precondition to unlocking the value of free expression. For example, in Keegstra, at p. 766, this Court noted that “it is partly through a clash with extreme and erroneous views that truth and the democratic vision remain vigorous and alive” (see also Committee for the Commonwealth of Canada v. Canada, [1991] 1 S.C.R. 139, at pp. 173 and 175, per L’Heureux-Dubé J., concurring; Grant v. Torstar Corp., 2009 SCC 61, [2009] 3 S.C.R. 640, at para. 49). While counterspeech is not necessarily a complete solution to harmful expression (see Keegstra, at 2023 SCC 14 (CanLII) Soc. Philos. 155, at pp. 155-56; P. Horwitz, “Citizenship and Speech. A Review of