focuses on content, that is, if it applies to "particular speech because of the topic discussed or the idea or message expressed." Reed, 135 S. Ct. at 2227. "This commonsense meaning of the phrase 'content based' requires a court to consider whether a regulation of speech 'on its face' draws distinctions based on the message a speaker conveys." Id. Content-based regulations are subject to strict scrutiny, which requires the government to demonstrate "a compelling interest and . . . narrow[] tailor[ing] to achieve that interest." Id. at 2231 (quoting Ariz. Free Enter. Club's Freedom Club PAC v. Bennett, 564 U.S. 721, 734 (2011)). Narrow tailoring in the strict scrutiny context requires the statute to be "the least restrictive means among available, effective alternatives." Ashcroft v. Am. Civil Liberties Union, 542 U.S. 656, 666 (2004). In contrast, content-neutral lesser level of justification. regulations require a These laws do not apply to speech based on or because of the content of what has been said, but instead "serve[] purposes unrelated to the content of expression." Ward v. Rock Against Racism, 491 U.S. 781, 791 (1989). principal inquiry in determining content "The neutrality . . . is whether the government has adopted a regulation of speech because of disagreement with the message it conveys. purpose is the controlling consideration. The government's A regulation that serves purposes unrelated to the context of expression is deemed neutral . . . ." Id. (citation - 12 - omitted). Content-neutral

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