[Senate Hearing 119-290]
[From the U.S. Government Publishing Office]


                                                        S. Hrg. 119-290

                 SHUT YOUR APP: HOW UNCLE SAM JAWBONED 
                   BIG TECH INTO SILENCING AMERICANS
=======================================================================

                                HEARING

                               BEFORE THE

                         COMMITTEE ON COMMERCE,
                      SCIENCE, AND TRANSPORTATION
                          UNITED STATES SENATE

                    ONE HUNDRED NINETEENTH CONGRESS

                             FIRST SESSION

                               __________

                            OCTOBER 8, 2025

                               __________

    Printed for the use of the Committee on Commerce, Science, and 
                             Transportation
                             
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                Available online: http://www.govinfo.gov
                
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                   U.S. GOVERNMENT PUBLISHING OFFICE                    
62-821 PDF                  WASHINGTON : 2026
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       SENATE COMMITTEE ON COMMERCE, SCIENCE, AND TRANSPORTATION

                    ONE HUNDRED NINETEENTH CONGRESS

                             FIRST SESSION

                       TED CRUZ, Texas, Chairman
JOHN THUNE, South Dakota             MARIA CANTWELL, Washington, 
ROGER WICKER, Mississippi                Ranking
DEB FISCHER, Nebraska                AMY KLOBUCHAR, Minnesota
JERRY MORAN, Kansas                  BRIAN SCHATZ, Hawaii
DAN SULLIVAN, Alaska                 EDWARD MARKEY, Massachusetts
MARSHA BLACKBURN, Tennessee          GARY PETERS, Michigan
TODD YOUNG, Indiana                  TAMMY BALDWIN, Wisconsin
TED BUDD, North Carolina             TAMMY DUCKWORTH, Illinois
ERIC SCHMITT, Missouri               JACKY ROSEN, Nevada
JOHN CURTIS, Utah                    BEN RAY LUJAN, New Mexico
BERNIE MORENO, Ohio                  JOHN HICKENLOOPER, Colorado
TIM SHEEHY, Montana                  JOHN FETTERMAN, Pennsylvania
SHELLEY MOORE CAPITO, West Virginia  ANDY KIM, New Jersey
CYNTHIA LUMMIS, Wyoming              LISA BLUNT ROCHESTER, Delaware
                 Brad Grantz, Republican Staff Director
           Nicole Christus, Republican Deputy Staff Director
                   Lila Harper Helms, Staff Director
                 Melissa Porter, Deputy Staff Director
                           
                           C O N T E N T S

                              ----------                              
                                                                   Page
Hearing held on October 8, 2025..................................     1
Statement of Senator Schmitt.....................................     1
    Prepared statement of Hon. Ted Cruz, U.S. Senator from Texas.     3
Statement of Senator Cantwell....................................     4
Statement of Senator Klobuchar...................................    30
Statement of Senator Fischer.....................................    31
Statement of Senator Moreno......................................    35
    Letter dated April 11, 2018 to Hon. Ajit Pai from Senators 
      Cantwell, Udall, Murray, Warren, Wyden, Markey, Blumenthal, 
      Smith, Sanders, Merkley, Baldwin and Booker................    36
Statement of Senator Rosen.......................................    47
Statement of Senator Blackburn...................................    49
Statement of Senator Markey......................................    51
Statement of Senator Peters......................................    53
Statement of Senator Lujan.......................................    55
Statement of Senator Blunt Rochester.............................    57
Statement of Senator Hickenlooper................................    60

                               Witnesses

Eugene Volokh, Thomas M. Siebel Senior Fellow, Hoover 
  Institution, Stanford University...............................     6
    Prepared statement...........................................     8
Alex Berenson, Independent Journalist and Author.................    18
    Prepared statement...........................................    20
Sean Davis, Chief Executive Officer, The Federalist..............    21
    Prepared statement...........................................    23
Gene Kimmelman, Senior Fellow, Tobin Economic Policy Center, Yale 
  University.....................................................    26
    Prepared statement...........................................    27

                                Appendix

Letter dated October 8, 2025 to Hon. Ted Cruz and Hon. Maria 
  Cantwell from The Leadership Conference on Civil and Human 
  Rights.........................................................    65
Writers Guild of America West (WGAW) and Writers Guild of America 
  East (WGAE), prepared statement................................    69
Letter dated October 3, 2024 to Hon. Jessica Rosenworcel, Hon. 
  Anna Gomez and Hon. Geoffrey Starks from Senator Mike Lee......    22
Letter dated June 8, 2022 to Hon. Jessica Rosenworcel from 
  Senator Marco Rubio, Senator Rick Scott, Senator Tom Cotton; 
  and Members of Congress: Carlos Gimenez, Maria Elvira Salazar 
  and Mario D!az-Balart..........................................    75
Response to written questions submitted to Eugene Volokh by:
    Hon. Ted Cruz................................................    77
    Hon. Maria Cantwell..........................................    78
Response to written questions submitted to Gene Kimmelman by:
    Hon. Maria Cantwell..........................................    79
    Hon. Amy Klobuchar...........................................    81

 
                             SHUT YOUR APP:
        HOW UNCLE SAM JAWBONED BIG TECH INTO SILENCING AMERICANS

                              ----------                              


                       WEDNESDAY, OCTOBER 8, 2025

                                       U.S. Senate,
        Committee on Commerce, Science, and Transportation,
                                                    Washington, DC.
    The Committee met, pursuant to notice, at 10:31 a.m., in 
room SR-253, Russell Senate Office Building, Hon. Eric Schmitt, 
presiding.
    Present: Senators Schmitt [presiding], Fischer, Blackburn, 
Sullivan, Moreno, Sheehy, Cantwell, Klobuchar, Markey, Peters, 
Rosen, Lujan, Hickenlooper, Fetterman, and Blunt Rochester.

            OPENING STATEMENT OF HON. ERIC SCHMITT, 
                   U.S. SENATOR FROM MISSOURI

    Senator Schmitt [presiding]. We will call this Commerce, 
Science, and Transportation Committee meeting to order.
    The author of the great book ``Dune'', Frank Herbert, set 
the table for what techno-totalitarianism looked like. Once men 
turned their thinking over to machines in the hope that this 
would set them free, but that only permitted other men with 
machines to enslave them.
    In the West, we are headed down this path toward thought 
crime enslavement. In the United Kingdom, 30 Brits are arrested 
per day for speech-related offenses. In the EU, the Digital 
Services Act is creating a censorship regime that would make 
Communist China blush. In the United States, before President 
Trump's return to power, the American vast censorship 
enterprise sought to control speech, to control how we think, 
and to influence national discourse and elections.
    In 2022, as the Attorney General of Missouri, I filed a 
landmark lawsuit, Missouri v. Biden, which Justice Alito called 
one of the most important First Amendment cases in American 
history. Through the lawsuit uncovered a vast censorship regime 
perpetrated by the Biden administration, I saw all the e-mails, 
I saw all the text messages. I deposed senior government 
officials including Anthony Fauci.
    Missouri v. Biden uncovered for the American people how the 
Biden administration built one of the largest censorship 
operations in American history by working in secret through 
third parties, pressuring, bullying, threatening, jawboning big 
tech into suppressing viewpoints that they disagreed with.
    Jen Saki boasted about flagging disinformation with 
Facebook. The Biden White House was revealed to have been 
backchanneling with YouTube about suppressing disfavored 
speech, suppressing things like the lab-leak theory. White 
House Digital Director Rob Flaherty pressured platforms like 
Facebook and YouTube to censor all kinds of COVID-related 
speech. Joe Biden said Facebook was killing people.
    Last week, Chairman Cruz and the Senate Commerce Committee 
released a report that revealed more details about how the 
Biden administration, as part of this larger censorship 
operation, weaponized the Cybersecurity and Infrastructure 
Security Agency, or CISA, into an agent of censorship, 
pressuring big tech to police speech.
    The Biden administration's collusion with big tech and non-
governmental organizations to censor speech, infringed on the 
individual freedoms of millions of Americans to limit what they 
could say, what they could hear, and what they could read.
    Fortunately, President Trump won a historic victory and on 
January 20, 2025, the first day of his second Presidential 
term, President Trump signed an executive order titled 
``Restoring Freedom of Speech and Ending Federal Censorship''. 
But the story of censorship does not begin and end with the 
Federal Government. Big tech was censored--was censoring long 
before Presidential job owning and I imagine will continue to 
censor long after.
    Here are some instances of pre-Biden censorship. All of big 
tech censored the Hunter Biden laptop story. Google banned 
COVID skepticism. Twitter shadow banned and suspended 
conservatives. Facebook throttled posts from pages like The 
Federalist in the New York Post. Facebook flagged and removed 
posts questioning voter ID laws and ballot harvesting.
    Two of today's witnesses, Alex Berenson and Sean Davis were 
direct targets of this censorship operation and were 
deplatformed, shadow banned and silenced for their viewpoints. 
Congress should address this problem with decisive legislative 
action like my Collude Act or my Censorship Accountability Act, 
both of which hold big tech and government sensors accountable.
    I look forward to hearing from our witnesses about what 
Congress and this Committee can do to make sure that no 
American, regardless of their political leanings, ever learns 
that the Federal Government, entrusted with protecting their 
First Amendment Rights, is actually working to undermine them 
behind closed doors.
    Our Founding Fathers recognized that freedom of speech is 
vital. Protecting it is first and foremost in the Bill of 
Rights. While some argued that free speech was already 
protected because the Constitution did not give the government 
power to censor, the framers went further, affirmatively 
restricting government intrusion.
    The First Amendment is the beating heart of our 
Constitution. Free speech is not just instrumental but an end 
to itself in the digital age with all the peril and possibility 
that accompanies it, the struggle for free speech is the 
struggle for civilization itself.
    I want to thank the witnesses for being here today and look 
forward to their testimony.
    And I will, before I turn it over the Ranking Member for 
her opening remarks, request that Chairman Cruz's opening 
statement be entered into the record.
    Without objection.
    [The prepared statement of Chairman Cruz follows:]

      Prepared Statement of Hon. Ted Cruz, U.S. Senator from Texas
    In a free society, the people govern--not by mob or might--but by 
reasoned argument and the rule of law. Essential to keeping a society 
free is the ability of a citizenry to speak freely and debate openly 
without fear of government reprisal. That ability--to think and speak 
one's mind--enables a society to hold its government to account. It's 
so critical that our Founders made this natural right a 
constitutionally protected one.
    The First Amendment is a powerful weapon against the government's 
ability to publicly censor its own citizens. But in recent years, we 
have seen the government censor in secret through third parties, 
``jawboning'' Big Tech into suppressing user content, often under the 
guise of ``safety'' or ``national security.''
    It starts subtly. Officials say they are combatting foreign 
disinformation campaigns from the Russians or the Chinese. Next, they 
clamp down on anyone re-posting such content. Then, government 
officials curtail speech that undermines their own positions.
    Tweeting about COVID-19 vaccine mandates or the efficacy of wearing 
a mask? Sorry, that's a ``safety'' issue. Questioning mail-in voting? 
That's a threat to critical election infrastructure.
    And so, our government becomes the speech police--the arbiter of 
truth--silencing those that disagree.
    Last week, I released a report detailing how the Biden 
administration weaponized the Cybersecurity and Infrastructure Security 
Agency to pressure Big Tech into policing speech. Two of today's 
witnesses--Alex Berenson and Sean Davis--were personally targeted by 
our government. At the behest of government officials, Mr. Berenson was 
completely deplatformed for having the temerity to challenge the Biden 
COVID narrative. Mr. Davis was shadow-banned for questioning the 
integrity of mail-in voting.
    But the silencing didn't stop there. The Biden administration 
sought to bring its censorship playbook into the Age of AI. It ``volun-
told'' AI developers to allow the National Institute of Standards and 
Technology to test AI products for misinformation and ``harmful'' 
speech. The National Science Foundation funded propaganda tools.
    By controlling AI inputs and outputs, the Biden administration was 
deciding what information Americans could see and consume--an effort 
that continues with laws in California, Colorado, and New York.
    Now censorship is growing around the world. In the United Kingdom, 
more than 12,000 Britons are arrested every year for speech-related 
offenses, according to the Times of London. My CISA (siss-uh) report 
shows why, in this context, the United States must remain a free speech 
beacon, zealously guarding against censorship regardless of who is in 
office.
    A few weeks ago, I received a letter from nearly every Democrat on 
this Committee calling for a hearing to stop an ``unprecedented attack 
on the First Amendment.'' The letter rightly stated that ``government 
officials cannot attempt to coerce private parties in order to punish 
or suppress views that the government disfavors.''
    But my colleagues weren't referring to the silencing of Messrs. 
Berenson and Davis or any of the other countless Americans censored 
during the previous administration. They were coming to the defense of 
Jimmy Kimmel, whose unpopular show was suspended by ABC following 
critical comments from the FCC Chairman.
    I've been clear on my views about Chairman Carr's comments.
    But I must ask my colleagues: Where were you when the Biden 
administration was silencing the American people?
    Maybe it's too much to ask Democrats to defend the First Amendment 
regardless of who is in power, not just when it is politically 
convenient.
    No government official--regardless of party--should be engaged in 
jawboning. The First Amendment is not about opinions you agree with. 
It's not about opinions that are right and reasonable. The First 
Amendment is about opinions that you passionately disagree with and the 
right of others to express them. I am one who agrees with John Stuart 
Mill: the best solution for bad ideas, for bad speech, is more speech 
and better ideas. We don't need to use brute force to silence them 
because truth is far more powerful than force.
    In the coming weeks, I will be introducing legislation to prohibit 
government jawboning and empower Americans to hold government officials 
accountable.
    As we'll hear today, Alex Berenson and Sean Davis face major 
hurdles in seeking remedies after the government launched secret 
censorship campaigns against them. My bill will fix that problem.
    I'll give my Democrat colleagues a chance to redeem themselves: 
Join me in standing up for free speech by working to advance this 
legislation and stop censorship by government officials.
    I thank the witnesses who are here with us today, and I look 
forward to this critical discussion about how we can protect freedom of 
thought in our country.

    Senator Schmitt. Ranking Member Cantwell.

               STATEMENT OF HON. MARIA CANTWELL, 
                  U.S. SENATOR FROM WASHINGTON

    Senator Cantwell. Thank you. Thank you, Mr. Chairman. And 
welcome to our witnesses. Thank you for joining us this 
morning. These issues of the media, and consumers, and free 
speech, very important issues for us to discuss in an era where 
consumers are paying more, where not enough competition exists, 
where deals are getting done that lead to fewer choices, less 
local news. I do have an important question. Where is Chairman 
Carr?
    Americans are paying and spending more money on content 
that used to be free more than ever before. And just a few 
weeks ago, we witnessed a deeply troubling episode. The FCC 
Chairman demanding ABC take immediate action against Jimmy 
Kimmel for tasteless remarks and saying, quote, ``We can do 
this the easy way or the hard way'', end quote. A line that 
Senator Cruz rightly criticized as something quote, ``Right out 
of Goodfellows'', end quote.
    Within hours, the Nation's largest ABC affiliate, NextStar 
and Sinclair, announced they would preempt the show 
indefinitely, and shortly thereafter, ABC suspended Jimmy 
Kimmel Live altogether. While ABC, NextStar, and Sinclair have 
since returned Mr. Kimmel to the air, that chain of events 
should alarm every American, because the power of the FCC was 
never meant to weaponize against a President or political 
targets.
    Let me be clear. Chairman Carr does not have the authority 
to police speech, nor does he or the White--that he or the 
White House finds offensive. He does not have the authority to 
threaten licenses based on content decisions. And this is 
especially true when those same companies have mergers and 
licensings pending before the FCC.
    That is exactly the kind of political interference, 
chilling effect on free speech that the First Amendment was 
designed to prevent. We need to hold Chairman Carr accountable 
for these threats. And that is why I have called on us to have 
a hearing and hopefully that will happen sometime in the near 
future.
    There is a need to have oversight on this, and I hope that 
this hearing does happen without further delay. Professor 
Volokh, am I saying that right, Volokh?
    Mr. Volokh. Yes.
    Senator Cantwell. Thank you--said in his testimony, quote, 
``FCC Chairman Brendan Carr's statement about Jimmy Kimmel may 
likewise have threatened retaliation in a way that would 
violate the First Amendment'', end quote.
    So the point on this there is broad agreement. Free 
expression is not a partisan issue. It is the bedrock of our 
democracy. So this is in a long list of issues about the First 
Amendment, I think, the President is making pretty much a 
standard issue.
    Just last week, the Federal Court found that the 
administration violated the First Amendment by arresting, 
detaining, and deporting non-citizen students and faculty 
members for their pro-Palestinian advocacy. This follows the 
White House revocation of the Associated Press' credentials for 
refusal to use the term, ``Gulf of Mexico'', clearly an attempt 
to police the language and intimidate free speech.
    Meanwhile, the administration continues to wield the full 
power of the Federal Government to retaliate against law firms 
the President does not like and threaten funding for 
universities he disfavors.
    It is alarming to see the administration use its regulatory 
and informal authority to unlawfully and infringe on free 
speech, the free press, and the First Amendment. And it is 
important that we also understand the broader context here. 
That is why Mr. Kimmelman, I am so glad to see you here today.
    Local journalism in America is already under extraordinary 
strain. The Commerce Committee has documented how online 
platforms monopolize advertising, siphon revenue away from 
local newspapers and broadcasters, and the result has been 
newsroom closures, layoffs across the country, and even as the 
public trust in local journalism remains at an all-time high.
    At the same time, media consolidation has been concentrated 
into fewer hands. Since 2005, the U.S. has lost almost one-
third of its newspapers. This year alone, 127 newspapers 
closed. Nearly 55 million Americans have limited or no access 
to local news, disproportionately affecting rural areas. That 
leaves new outlets more vulnerable to political and corporate 
pressures and leaves the public without further resources of 
getting to true competition, which I believe gets us to the 
truth.
    If Chairman Carr can threaten one network over a single 
late-night host and his message, what kind of message does that 
send to local broadcasters in Seattle or Houston? Do they lose 
their licenses if they are reporting or they are crossing the 
White House? This kind of intimidation undermines the very 
foundation of the free press.
    I want to be clear, protecting a free press does not mean 
ignoring the dangers of harmful hate speech. I have expressed 
concerns about companies like Facebook, Google, and X on issues 
that really did threaten the lives of individuals. And I know 
that we will hear a lot about what the Biden administration did 
in these areas. But let us not forget the Supreme Court 
rejected allegations of the Biden administration censorship 
because the record showed that social media companies, 
``Continued to exercise their independent judgment'', and had, 
quote, ``Independent incentives to moderate content'' end 
quote. I am sure we will talk a lot about this.
    Persuading companies to enforce their own content 
moderation policies is not the same, is not the same as 
threatening them with retaliation. And that is precisely what 
Chairman Carr did when he publicly threatened ABC, an entity 
over which the FCC holds direct regulatory power, to take 
action over the speech the administration did not like.
    Holding companies accountable for amplifying harm is not 
the same as expressing Constitutional protected speech the 
President finds politically inconvenient. That is what we 
should be focusing on today. making sure the FCC, as a Federal 
agency, cannot use its authority to threaten or intimidate the 
media to ensure the licensed decisions are based on the law and 
not on political coercion. I hope today we can speak clearly 
about this and do what we can to make sure that we show that 
free speech is something we all agree on.
    Thank you, Mr. Chairman. And look forward to hearing from 
the witnesses.
    Senator Schmitt. Thank you, Ranking Member.
    One point of clarification for the record, Murthy v. 
Missouri was not decided that way. It was sent back to lower 
court for additional arguments on standing, not on the merits.
    I would like to introduce our witnesses for today. Our 
first witness is Mr. Eugene Volokh, a Senior Fellow with the 
Hoover Institution at Stanford University and a Professor of 
Law Emeritus at UCLA School of Law. He is an expert in First 
Amendment Law, and his writings have been cited in over 300 
court opinions including ten Supreme Court cases. Welcome.
    Our second witness is Mr. Alex Berenson, an author, 
independent journalist, and victim of the Biden 
administration's embargo on free speech. I look forward to 
hearing from Mr. Berenson and his story, and what we can do to 
preserve speech online.
    Our third witness is Mr. Sean Davis, Chief Executive 
Officer and Co-founder of The Federalist, a conservative news 
outlet that was subject to censorship and demonetization 
efforts for speaking out against the COVID-19 shutdowns.
    And our final witness is Mr. Gene Kimmelman, a Senior 
Policy Fellow at Yale's Tobin Economic Policy Center and a 
Senior Research Fellow at the Harvard Kennedy School's Center 
for Business and Government.
    And at this point would recognize Mr. Volokh for your own 
opening statement. Thank you for being here.

  STATEMENT OF EUGENE VOLOKH, THOMAS M. SIEBEL SENIOR FELLOW, 
            HOOVER INSTITUTION, STANFORD UNIVERSITY

    Mr. Volokh. Thank you. Thank you very much for having me. 
This is a topic that is I think very important, and something 
that I have been very interested in myself. I should also say 
by sheer accident turns out that today is 50 years to the day 
since my parents brought me to the United States from the then 
Soviet Union. So thank you to the United States of America for 
letting me in.
    Very, very glad to be here. So I wanted to speak briefly 
about the First Amendment Law on the subject both that which is 
settled and that which is not entirely certain. So one thing 
that I think is worth noting is that the word ``jawboning'' is 
sometimes used in two different senses. One sense is coercion, 
when the government is essentially threatening someone with 
retaliation as a means of suppressing either that person's 
speech or getting that person to suppress somebody else's 
speech.
    A second one is what might call persuasion and maybe 
pressure, short of coercion. When the government is kind of 
urging people, some people might say again pressuring people to 
restrict, again, either their own speech or other people's 
speech.
    So the government coercion is generally unconstitutional. I 
think, indeed, in the remarks of Chairman Carr seemed to be an 
attempt at coercion. Whether or not they actually caused the 
suspension of Jimmy Kimmel, I think they were an attempt to do 
something that the Constitution does not allow.
    Just last year the Supreme Court found in NRA v. Vullo, 
that the National Rifle Association had adequately alleged 
coercion on the part of New York government authorities aimed 
at trying to get insurance companies to limit ties to the NRA 
as a means of trying to interfere with the NRA's political 
advocacy. So that is pretty well settled for that 
constitutional problem.
    Now, what about persuasion? Well, in some situations, the 
government is entitled to urge entities to not speak. You can 
imagine a situation where a police chief calls up a newspaper 
and says: Look, I am not trying to coerce you. I know I cannot 
coerce you. You can publish this article you are about to 
publish, but it is going to interfere with us catching the 
criminals, and you would not want that, right? So could I just 
ask you please to do this?
    You know, some amount of that has got to be permissible. Or 
to take another example as to misinformation. Somebody calls up 
a reporter and says: You are about to publish this article or 
this op-ed and it is just false. It is just wrong. Don't you 
want to be corrected on this?
    Again, some amount of that, it seems to me, has to be 
constitutionally permissible. At the same time, there is a 
complication because the line between coercion and persuasion 
is often very hard to draw. And that is particularly true when 
the speaker has power over the listener.
    The Supreme Court has most clearly recognized this in the 
employment context. Employers are entitled to talk to their 
employees, including about unionization. They are entitled to 
explain why they think unionizing would be a mistake. But the 
court has recognized that in looking at what the employer says 
and seeing if the employer is speaking coercively, one has to 
appreciate that the employee is dependent on the employer, and 
may pick up coercive messages even in situations where it is 
not expressed on the face of this statement.
    And I think the same thing is true when the government, 
which is a very powerful regulator, is talking to people in a 
regulated industry. There are times when what might sound on 
its face, or let us say just on the bare paper might look like 
it is not coercive may in fact, in context, be quite coercive.
    Another concern is the merger of government and private 
power when it is not just kind of occasional conversations but 
a systemic mechanism for trying to restrict speech. An analogy 
might be a few amendments down in the Fourth Amendment. If you 
have a roommate and you notice some evidence of crime and you 
call up the police, the police can use that evidence, because 
that is not a government search. The police did not search for 
it. You did.
    On the other hand, if the police called you up and say: 
Hey, you know, not trying to coerce you, but could you please 
rummage through your roommate's papers? That does become a 
Fourth Amendment's--a search subject to the Fourth Amendment, 
precisely because it is encouraged, substantially encouraged by 
the police. The police become enmeshed with the private search. 
So that suggests that there is something similar may apply to 
the First Amendment.
    So let me just close with suggesting that this is, in fact, 
the right body to be dealing with a lot of these concerns. That 
some of these problems can only be solved through statutory 
action, through laws that maybe limit attempts at systemic 
persuasion and systemic suppression of speech even if it is not 
technically coercive.
    At laws that facilitate finding information about that, and 
at laws that actually provide a cause of action which the 
Congress has for over a century provided against state 
governments, but provided against the Federal Government, as 
well.
    [The prepared statement of Mr. Volokh follows:]

   Prepared Statement Eugene Volokh, Thomas M. Siebel Senior Fellow, 
                Hoover Institution, Stanford University
    Dear Chairman and Members of the Committee:

    Thank you for asking me to testify on the important First Amendment 
issues raised by government jawboning, a subject that I have been 
studying for several years. I will try to offer a big picture view of 
the matter, rather than focusing on the particular factual details 
related to, for instance, the various interactions between CISA (the 
Cybersecurity and Infrastructure Security Agency) and social media 
platforms.
    ``To jawbone'' has been defined as ``to attempt to persuade or 
pressure by the force of one's position of authority,'' \1\ especially 
when done by the government. That in turn reflects two possible 
meanings:
---------------------------------------------------------------------------
    \1\ See, e.g., Collins Dictionary, https://
www.collinsdictionary.com/us/dictionary/english/jawboning (quoting 
Irwin Stelzer, GM Has Riled the Jawboner-in-Chief, Times (London), Dec. 
2, 2018).

  (1)  government officials trying to persuade through the force of 
        their reasoning, though strengthened by their authoritativeness 
---------------------------------------------------------------------------
        and resulting credibility and influence;

  (2)  government officials trying to coerce through the explicit or 
        implicit threat of retaliation stemming from their position of 
        authority, e.g., through the threat of enforcement or 
        regulation.

    As a practical matter, the two meanings are closely intertwined, 
especially since it may be hard to tell whether there is an implicit 
``or else'' behind a request. As a legal matter, though, there may be a 
substantial distinction, at least when it comes to the government 
trying to pressure entities into shutting down third parties' speech.
           I. Government Coercion: Generally Unconstitutional
    Say the government doesn't like some speech, though the speech is 
constitutionally protected against direct punishment (i.e., the speech 
doesn't fit into one of the narrow First Amendment exceptions, for 
example the exception for true threats of criminal conduct). The 
government therefore demands that a private entity that has the private 
power to control such speech--say, a social media platform, a 
bookstore, a financial intermediary--suppress the speech, or else face 
some coercive government action. That generally violates the First 
Amendment. ``[A] government official cannot do indirectly what she is 
barred from doing directly: A government official cannot coerce a 
private party to punish or suppress disfavored speech on her behalf.'' 
\2\
---------------------------------------------------------------------------
    \2\ NRA v. Vullo, 602 U.S. 175, 190 (2024).
---------------------------------------------------------------------------
    The long-standing Supreme Court precedent addressing that issue is 
Bantam Books, Inc. v. Sullivan (1963), in which a state commission 
threatened to prosecute stores that sold books it deemed pornographic, 
including books that were protected by the First Amendment.\3\ 
Likewise, in NRA v. Vullo (2024), the Court held that the NRA could sue 
New York financial regulators under the First Amendment for allegedly 
coercing banks and insurance companies ``to cut their ties with the NRA 
in order to stifle the NRA's gun-promotion advocacy.'' \4\ Under these 
precedents, FCC Chairman Brendan Carr's statements about Jimmy Kimmel 
may likewise have threatened retaliation in a way that would violate 
the First Amendment.\5\
---------------------------------------------------------------------------
    \3\ 372 U.S. 58 (1963).
    \4\ 602 U.S. at 197. Note that I was one of the NRA's lawyers in 
this case.
    \5\ The statements on the Benny Johnson podcast, https://x.com/
bennyjohnson/status/1968359685045838041, were:

    Broadcasters . . . have a license granted by us at the FCC, and 
that comes with it an obligation to operate in the public interest. . . 
 

    We can do this the easy way or the hard way. These companies can 
find ways to change conduct, to take action, frankly, on Kimmel or 
there is going to be additional work for the FCC ahead. . . .

    There's calls for Kimmel to be fired. I think you could certainly 
see a path forward for suspension over this.

    The FCC has a rule that prohibits ``broadcast news distortion,'' 
https://www.fcc.gov/broadcast-news-distortion, and it's possible that--
given the lower First Amendment protection given to broadcasting than 
to, say, newspapers or the Internet--the FCC might be able to impose a 
modest fine for Kimmel's statement or even just issue an admonition. 
But there appears to be no justification for the government's demanding 
outright suspension of the Kimmel show based on one false statement, 
nor does there appear to be any precedent in the past four decades for 
anything more than a token punishment in such a situation.
---------------------------------------------------------------------------
    Lower court cases have found that there could be impermissible 
coercion even absent express threat of prosecution or regulatory 
action, so long as the threat is sufficiently implicit. Consider two 
cases that were favorably cited by the Supreme Court in NRA v. Vullo:

    1. The president of the Borough of Staten Island sent a letter to a 
billboard company urging it to take down an antihomosexuality 
billboard. The letter closed with:

        Both you and the sponsor of this message should be aware that 
        many members of the Staten Island community, myself included, 
        find this message unnecessarily confrontational and offensive. 
        As Borough President of Staten Island, I want to inform you 
        that this message conveys an atmosphere of intolerance which is 
        not welcome in our Borough.

        P.N.E. Media owns a number of billboards on Staten Island and 
        derives substantial economic benefits from them. I call on you 
        as a responsible member of the business community to please 
        contact Daniel L. Master, my legal counsel and Chair of my 
        Anti-Bias Task Force . . . to discuss further the issues I have 
        raised in this letter.

    Potentially unconstitutional, the Second Circuit held in Okwedy v. 
Molinari (2003):

        [A] jury could find that Molinari's letter contained an 
        implicit threat of retaliation if PNE failed to accede to 
        Molinari's requests. In his letter, Molinari invoked his 
        official authority as ``Borough President of Staten Island'' 
        and pointed out that he was aware that ``P.N.E. Media owns a 
        number of billboards on Staten Island and derives substantial 
        economic benefits from them.'' He then ``call[ed] on'' PNE to 
        contact Daniel L. Master, whom he identified as his ``legal 
        counsel and Chair of my Anti-Bias Task Force.''

        Based on this letter, PNE could reasonably have believed that 
        Molinari intended to use his official power to retaliate 
        against it if it did not respond positively to his entreaties. 
        Even though Molinari lacked direct regulatory control over 
        billboards, PNE could reasonably have feared that Molinari 
        would use whatever authority he does have, as Borough 
        President, to interfere with the ``substantial economic 
        benefits'' PNE derived from its billboards in Staten Island.\6\
---------------------------------------------------------------------------
    \6\ 333 F.3d 339, 341, 342, 344 (2d Cir. 2003).

    2. The Sheriff of Cook County in Illinois sent letters to 
Mastercard and Visa saying, ``As the Sheriff of Cook County, a father 
and a caring citizen, I write to request that your institution 
immediately cease and desist from allowing your credit cards to be used 
to place ads on websites like Backpage.com [which hosted ads for sex-
related services].'' Potentially unconstitutional, the Seventh Circuit 
held in Back-page.com, LLC v. Dart (2015). The court went through the 
---------------------------------------------------------------------------
Sheriff's letter in detail and concluded:

        And here's the kicker: ``Within the next week, please provide 
        me with contact information for an individual within your 
        organization that I can work with [harass, pester] on this 
        issue.'' The ``I'' is Sheriff Dart, not private citizen Dart--
        the letter was signed by ``Thomas Dart, Cook County Sheriff.''

        And the letter was not merely an expression of Sheriff Dart's 
        opinion. It was designed to compel the credit card companies to 
        act by inserting Dart into the discussion; he'll be chatting 
        them up.

        Further insight into the purpose and likely effect of such a 
        letter is provided by a strategy memo written by a member of 
        the sheriff's staff in advance of the letter. The memo 
        suggested approaching the credit card companies (whether by 
        phone, mail, e-mail, or a visit in person) with threats in the 
        form of ``reminders'' of ``their own potential liability for 
        allowing suspected illegal transactions to continue to take 
        place'' and their potential susceptibility to ``money 
        laundering prosecutions . . . and/or hefty fines.'' Allusion to 
        that ``susceptibility'' was the culminating and most ominous 
        threat in the letter.\7\
---------------------------------------------------------------------------
    \7\ 807 F.3d 229, 231-32 (7th Cir. 2015). The bracketed words, 
``harass, pester,'' were added by the court, presumably as an 
indication of how the court interpreted ``work with.'' See Complaint 
Exh. B at 7, Backpage.com, LLC v. Dart, No. 1:15-cv-06340 (N.D. Ill. 
July 21, 2015).

    3. Finally, consider a third example: The Biden administration's 
attempting to persuade social media platforms to block or remove posts 
on various topics, including ``the COVID-19 lab-leak theory, pandemic 
lockdowns, vaccine side-effects, election fraud, and the Hunter Biden 
laptop story.'' The Fifth Circuit concluded in Missouri v. Biden (2023) 
that some of the government's actions were likely unconstitutionally 
---------------------------------------------------------------------------
coercive:

        On multiple occasions, the officials coerced the platforms into 
        direct action via urgent, uncompromising demands to moderate 
        content And, more importantly, the officials threatened--both 
        expressly and implicitly--to retaliate against inaction. 
        Officials threw out the prospect of legal reforms and 
        enforcement actions while subtly insinuating it would be in the 
        platforms' best interests to comply. As one official put it, 
        ``removing bad information'' is ``one of the easy, low-bar 
        things you guys [can] do to make people like me''--that is, 
        White House officials--``think you're taking action.'' When the 
        officials' demands were not met, the platforms received 
        promises of legal regime changes, enforcement actions, and 
        other unspoken threats. That was likely coercive. . . .

        [M]any of the officials' asks were ``phrased virtually as 
        orders,'' like requests to remove content ``ASAP'' or 
        ``immediately.'' The threatening ``tone'' of the officials' 
        commands, as well as of their ``overall interaction'' with the 
        platforms, is made all the more evident when we consider the 
        persistent nature of their messages. . . . [T]here is [also] 
        plenty of evidence--both direct and circumstantial, considering 
        the platforms' contemporaneous actions--that the platforms were 
        influenced by the officials' demands. . . .

        [And] the speaker [had] ``authority over the recipient.'' [The 
        White House] enforces the laws of our country, and--as the head 
        of the executive branch--directs an army of Federal agencies 
        that create, modify, and enforce Federal regulations At the 
        very least, as agents of the executive branch, the officials' 
        powers track somewhere closer to those of the commission in 
        Bantam Books--they were legislatively given the power to 
        ``investigate violations and recommend prosecutions.''

        [T]he officials made express threats and, at the very least, 
        leaned into the inherent authority of the President's office. . 
        . . But, beyond express threats, there was always an ``unspoken 
        `or else.' '' [W]hen the platforms faltered, the officials 
        warned them that they were ``[i]nternally considering our 
        options on what to do,'' their ``concern[s] [were] shared at 
        the highest (and I mean highest) levels of the [White House],'' 
        and the ``President has long been concerned about the power of 
        large social media platforms.'' \8\
---------------------------------------------------------------------------
    \8\ 83 F.4th 350, 382 (5th Cir. 2023).

    The Supreme Court reversed the Fifth Circuit's decision on 
procedural grounds, so that decision is no longer binding precedent.\9\ 
The Court's opinion also cast doubt on the factual findings that the 
Fifth Circuit relied on.\10\ Nonetheless, the Fifth Circuit's analysis 
is a good illustration of how courts sometimes evaluate such 
allegations of coercion.
---------------------------------------------------------------------------
    \9\ 603 U.S. 43 (2024).
    \10\ Id. at 60 n.4.
---------------------------------------------------------------------------
                       II. Government Persuasion
                        A. Often Constitutional
    Now say the government simply tries to persuade various 
intermediaries--whether today's social media platforms or, as was the 
case in the recent past, bookstores, billboards, or payment 
processors--to stop carrying certain speech, without an express or 
implied threat of retaliation. Generally speaking, courts of appeals 
have said that this does not violate the First Amendment. To offer a 
few examples:
    1. In 1980, a New York City official sent a letter urging 
department stores not to carry ``a board game titled `Public 
Assistance--Why Bother Working for a Living.' '' The letter said the 
game ``does a grave injustice to taxpayers and welfare clients alike,'' 
and closes with, ``Your cooperation in keeping this game off the 
shelves of your stores would be a genuine public service.'' Not 
unconstitutional, said the Second Circuit in Hammerhead Enterprises, 
Inc. v. Brezenoff (1983):

        [T]he record indicates that Brezenoff's request to New York 
        department stores to refrain from carrying Public Assistance 
        was nothing more than a well-reasoned and sincere entreaty in 
        support of his own political perspective Where comments of a 
        government official can reasonably be interpreted as intimating 
        that some form of punishment or adverse regulatory action will 
        follow the failure to accede to the official's request, a valid 
        claim can be stated. . . . [But] appellants cannot establish 
        that this case involves either of these troubling 
        situations.\11\
---------------------------------------------------------------------------
    \11\ 707 F.2d 33, 34, 37, 38-39 (2d Cir. 1983).

    Note, though, that Brezenoff was the administrator of New York 
City's Human Resources Administration, with no enforcement authority 
against the department stores. How might the matter have looked had he 
been the sheriff or the head of some civil enforcement agency?
    2. Not long after, the U.S. Attorney General's Commission on 
Pornography sent letters to various corporations (such as 7-Eleven) 
urging them not to sell pornographic magazines:

        The Attorney General's Commission on Pornography has held six 
        hearings across the United States during the past seven months 
        on issues related to pornography. During the hearing in Los 
        Angeles, in October 1985, the Commission received testimony 
        alleging that your company is involved in the sale or 
        distribution of pornography. The Commission has determined that 
        it would be appropriate to allow your company an opportunity to 
        respond to the allegations prior to drafting its final report 
        section on identified distributors.

        You will find a copy of the relevant testimony enclosed 
        herewith. Please review the allegations and advise the 
        Commission on or before March 3, 1986, if you disagree with the 
        statements enclosed. Failure to respond will necessarily be 
        accepted as an indication of no objection.

        Please call Ms. Genny McSweeney, Attorney, at (202) 724-7837 if 
        you have any questions. Thank you for your assistance.

    Not unconstitutional, said the D.C. Circuit in Penthouse 
International, Ltd. v. Meese (1991):

        [T]he Advisory Commission had no tie to prosecutorial power nor 
        authority to censor publications. The letter it sent contained 
        no threat to prosecute, nor intimation of intent to proscribe 
        the distribution of the publications. . . .

        We do not see why government officials may not vigorously 
        criticize a publication for any reason they wish. As part of 
        the duties of their office, these officials surely must be 
        expected to be free to speak out to criticize practices, even 
        in a condemnatory fashion, that they might not have the 
        statutory or even constitutional authority to regulate. If the 
        First Amendment were thought to be violated any time a private 
        citizen's speech or writings were criticized by a government 
        official, those officials might be virtually immobilized.\12\
---------------------------------------------------------------------------
    \12\ 939 F.2d 1011, 1013, 1015-1016 (D.C. Cir. 1991).

    3. In the late 1990s, a New York state legislator and a New York 
congressman accused X-Men Security--a security organization connected 
to the Nation of Islam--of various conspiracies, ``asked government 
agencies to conduct investigations into its operations, questioned X-
Men's eligibility for an award of a contract supported by public funds, 
and advocated that X-Men not be retained.'' X-Men lost certain security 
contracts as a result. Also not unconstitutional, ruled the Second 
---------------------------------------------------------------------------
Circuit in X-Men Security, Inc. v. Pataki (1999):

        [J]ust as the First Amendment protects a legislator's right to 
        communicate with administrative officials to provide assistance 
        in securing a publicly funded contract, so too does it protect 
        the legislator's right to state publicly his criticism of the 
        granting of such a contract to a given entity and to urge to 
        the administrators that such an award would contravene public 
        policy. We see no basis on which X-Men could properly be found 
        to have a constitutional right to prevent the legislators from 
        exercising their own rights to speak.\13\
---------------------------------------------------------------------------
    \13\ 196 F.3d 56, 68, 70 (2d Cir. 1999).

    And it does appear that at least some such persuasion ought to be 
constitutionally acceptable. After all, government officials have a 
strong interest in conveying their views, including their views about 
what speech is harmful and should not be published. It's not clear 
whether they have a personal First Amendment right to do so in their 
official capacities.\14\ But there may still be real value to public 
discourse, and to their listeners, in their being able to do so--and 
thus it might not be a First Amendment violation in their asking 
intermediaries to sometimes choose to block certain speech.
---------------------------------------------------------------------------
    \14\ Compare Garcetti v. Ceballos, 547 U.S. 410, 421 (2006) 
(concluding that government officials generally don't have First 
Amendment rights when exercising their official duties); and David 
Fagundes, State Actors as First Amendment Speakers, 100 Nw. U. L. Rev. 
1637 (2006) (discussing uncertainty about when state officials may have 
First Amendment rights vis-a-vis the Federal government).
---------------------------------------------------------------------------
    For instance, national security officials might sometimes tell a 
news outlet, ``Look, we can't force you to do anything, but if you run 
this story it will lead to deaths of intelligence sources/damage to 
national security. Could you not run the story, or fuzz over some 
details, or delay it?'' The news outlet might find that to be valuable 
information. Reporters and editors might want to avoid causing deaths 
or harming national security, especially if the bulk of the story can 
still be reported with a bit of delay or slight modification.
    Likewise, law enforcement officials might reasonably and 
permissibly tell a newspaper or broadcaster, ``If you run this story 
right now, you'll tip off the criminals we're investigating/jeopardize 
witnesses. Don't you want us to fight crime effectively?'' The 
newspaper might say yes or no, assuming there's no context to make the 
statement coercive. I doubt such a request would violate the First 
Amendment.
    Or say that a newspaper is about to run an op-ed that alleges 
governmental misconduct. A government official learns of this--perhaps 
the editors call him to get his side of the story--and says, ``That's 
nonsense, and here's the evidence to prove that.'' Or he says, ``The 
allegations are so slanted as to be deceptive or unfair; here's the 
context that shows it.'' And then adds, ``Please don't run such an 
unfair story; it would be bad for us if you did, but it would also be 
bad for your reputation, when the truth comes out, and it would be bad 
for your readers, who would be misled.''
    That is a call for an intermediary (the newspaper) to block the 
publication of a third-party item (the op-ed). However, it is unlikely 
to be unconstitutional. Indeed, the newspaper may be quite pleased to 
learn the full story and thereby avoid publishing an op-ed that would 
make the newspaper look bad.
                  B. Potential Limits: Subtle Coercion
    At the same time, there may be limits on such persuasion. The first 
comes from the reality that the coercion/persuasion line is often hazy. 
One concern about government persuasion of intermediaries is that when 
the government asks, people who are subject to regulation by the 
government may hear this as demanding. As it happens, this concern has 
arisen in at least one other First Amendment context, and the reasoning 
in that context might be applicable here as well.
    That context is labor law. Since the 1940s--early in the Court's 
modern First Amendment jurisprudence--the Court has recognized that 
``employers' attempts to persuade to action with respect to joining or 
not joining unions are within the First Amendment's guarantee'' but not 
when ``to this persuasion other things are added which bring about 
coercion, or give it that character.'' \15\ In NLRB v. Gissel Packing 
Co. (1969), the Court made clear that the employer's power over 
employees should be considered in deciding whether the speech is likely 
to coerce:
---------------------------------------------------------------------------
    \15\ Thomas v. Collins, 323 U.S. 516, 537 (1945) (treating the 
matter as having been settled by NLRB v. Virginia Electric & Power Co., 
314 U.S. 469 (1941)); Virginia Electric & Power, 314 U.S. at 477 (``The 
employer in this case is as free now as ever to take any side it may 
choose on this controversial issue. But, certainly, conduct, though 
evidenced in part by speech, may amount, in connection with other 
circumstances, to coercion within the meaning of the Act'').

        Any assessment of the precise scope of employer expression, of 
        course, must be made in the context of its labor relations 
        setting [A]ny balancing of [the employer's and employee's] 
        rights must take into account the economic dependence of the 
        employees on their employers, and the necessary tendency of the 
        former, because of that relationship, to pick up intended 
        implications of the latter that might be more readily dismissed 
        by a more disinterested ear.\16\
---------------------------------------------------------------------------
    \16\ 395 U.S. 575, 617 (1969).

    Similar logic, I think, may apply when high-level executive 
officials, or those who speak for them, address intermediaries who are 
---------------------------------------------------------------------------
regulated by those officials or the officials' appointees:

        [A]ny balancing of [government speakers' and intermediaries'] 
        rights must take into account the economic dependence of the 
        [intermediaries] on their [regulators], and the necessary 
        tendency of the former, because of that relationship, to pick 
        up intended implications of the latter that might be more 
        readily dismissed by a more disinterested ear.

    This analogy would still leave government officials able to make 
requests in certain ways, just as employers remain able to speak in 
certain ways to employees about the possible consequences of 
unionization. But the officials would have to be more careful to make 
clear that the request carries no threat of retaliation.
    What sort of statement by the government would make clear that 
there is no such threat? That would doubtless turn on many factors. 
Thus, for instance, with regard to the requests sent to the social 
media platforms by CISA, the Fifth Circuit in Missouri v. Biden found 
sufficient evidence only that CISA ``significantly encouraged the 
platforms' content-moderation decisions''--the court didn't state that 
there was sufficient evidence that CISA was coercing the platforms, 
though the court did find sufficient evidence of coercion by some other 
government agencies.\17\
---------------------------------------------------------------------------
    \17\ See 83 F.4th at 391; cf. id. at 389 (stating, as to the FBI, 
that ``the platforms' decisions were significantly encouraged and 
coerced by the FBI'' (emphasis added)).
---------------------------------------------------------------------------
    I think, though, that if there were some serious concern about 
coercion, dispelling such concern would require considerably more than 
the disclaimer that CISA included in its e-mails:

        CISA affirms that it neither has nor seeks the ability to 
        remove or edit what information is made available on social 
        media platforms. CISA makes no recommendations about how the 
        information it is sharing should be handled or used by social 
        media companies. Additionally, CISA will not take any action, 
        favorable or unfavorable, toward social media companies based 
        on decisions about how or whether to use this information.\18\
---------------------------------------------------------------------------
    \18\ See The Mechanics of Government Censorship 14 (2025).

    Of course the social media companies' likely worry wouldn't have 
been that ``CISA''--an agency that itself lacks regulatory power over 
the companies--``will take . . . action . . . toward'' them. Rather, 
the worry would have been that some other, much more powerful, Federal 
government actors would take ``adverse government action,'' such as 
``antitrust enforcement and legal reforms'' \19\ or possibly law 
enforcement action of the sort that the FBI can engage in.\20\ In light 
of this, a disclaimer pointedly limited to retaliation by CISA was 
unlikely to do much good.
---------------------------------------------------------------------------
    \19\ 83 F.4th at 373.
    \20\ Id. at 388-89.
---------------------------------------------------------------------------
      C. Potential Limits: Merger of Government and Private Power
    There is also reason to think that at least sometimes the 
Constitution does constrain the merging of government and private 
power, at least when the government tries to use that merger to bypass 
the usual constraints on its powers--even in the absence of coercion. 
And even if the Constitution itself doesn't render such merging of 
power unconstitutional, there may be good reason to try to constrain 
such merging by statute.
    To begin, let's consider an analogy, three Amendments down: the 
Fourth Amendment. Say you rummage through a roommate's papers, find 
evidence that he's committing a crime, and send it to the police. 
Because you're a private actor, you haven't violated the Fourth 
Amendment. (Whether you committed some tort or crime is a separate 
question.)\21\ Because they didn't perform the search, the police 
haven't violated the Fourth Amendment either, and the evidence from 
this ``private search'' can be used against the roommate.
---------------------------------------------------------------------------
    \21\ See United States v. Phillips, 32 F.4th 865, 867 (9th Cir. 
2022); Burdeau v. McDowell, 256 U.S. 465, 475-476 (1921).
---------------------------------------------------------------------------
    But if the police ask you to rummage through the roommate's papers, 
that rummaging may constitute a search governed by the Fourth 
Amendment. ``[I]f a state officer requests a private person to search a 
particular place or thing, and if that private person acts because of 
and within the scope of the state officer's request,'' then the search 
would be subject to the constitutional constraints applicable to 
government searches.\22\ ``Police officers may not avoid the 
requirements of the Fourth Amendment by inducing, coercing, promoting, 
or encouraging private parties to perform searches they would not 
otherwise perform.'' \23\ Coercion is only one way a private search may 
become subject to the Fourth Amendment; inducement, promotion, or 
encouragement can also suffice.
---------------------------------------------------------------------------
    \22\ State v. Tucker, 330 Or. 85, 90 (2000) (applying the Oregon 
Constitution's Fourth Amendment analog; police request to tow truck 
driver to search items in car being towed), followed by State v. Lien, 
364 Or. 750, 778 (2019) (police request to trash company to pick up a 
person's trash in a particular way that would facilitate its being 
searched). See also United States v. Gregory, 497 F. Supp. 3d 243 (E.D. 
Ky. 2020) (similar fact pattern to Lien).
    \23\ George v. Edholm, 752 F.3d 1206, 1215 (9th Cir. 2014) (police 
request to doctor to do a rectal search). See also United States v. 
Ziegler, 474 F.3d 1184, 1190 (9th Cir. 2007) (police request to 
employer to search employee's work computer); United States v. Rosenow, 
50 F.4th 715, 733 (9th Cir. 2022) (recognizing that, even when a 
private party's search would normally be entirely legal, the 
government's ``encouragement'' of such a search may constitute ``state 
action'').
---------------------------------------------------------------------------
    Indeed, in Skinner v. Railway Labor Executives' Association (1989), 
the Supreme Court held that drug tests of railway employees that were 
authorized but not required by Federal regulations were subject to 
Fourth Amendment scrutiny:

        The Government has removed all legal barriers to the testing 
        authorized by Subpart D, and indeed has made plain not only its 
        strong preference for testing, but also its desire to share the 
        fruits of such intrusions. In addition, it has mandated that 
        the railroads not bargain away the authority to perform tests 
        granted by Subpart D. These are clear indices of the 
        Government's encouragement, endorsement, and participation, and 
        suffice to implicate the Fourth Amendment.\24\
---------------------------------------------------------------------------
    \24\ Skinner v. Railway Labor Executives Assn', 489 U.S. 602, 615-
16 (1989).

    Considering the extensive regulation of railroads by the 
government, the railway companies might have felt special pressure to 
view the government's ``encouragement'' and ``endorsement'' as a 
command. Yet the Court did not rely on the theory that the government 
had indeed coerced the railroads to perform the tests. It appeared to 
be enough that it ``encourage[d], endorse[d], and participat[ed]'' in 
the tests. The same may apply to social media platforms, especially 
(but perhaps not only) in a political environment where there is talk 
of possible regulation, such as through antitrust law or by modifying 
Section 230 immunity.\25\
---------------------------------------------------------------------------
    \25\ See Murthy, 603 U.S. at 80-81 (Alito, J., dissenting) 
(reasoning that ``internet platforms, although rich and powerful, are 
at the same time far more vulnerable to Government pressure than other 
news sources'' because ``[t]hey are critically dependent on the 
protection provided by Sec. 230 of the Communications Decency Act of 
1996,'' which Congress might threaten to withdraw; ``[t]hey are 
vulnerable to antitrust actions''; and, ``because their substantial 
overseas operations may be subjected to tough regulation in the 
European Union and other foreign jurisdictions, they rely on the 
Federal Government's diplomatic efforts to protect their interests'').
---------------------------------------------------------------------------
    Likewise, ``In the Fifth Amendment context, courts have held that 
the government might violate a defendant's rights by coercing or 
encouraging a private party to extract a confession from a criminal 
defendant.'' \26\ More broadly, the Supreme Court held in Blum v. 
Yaretsky (1982), a Due Process Clause case, that ``a State normally can 
be held responsible for a private decision only when it has exercised 
coercive power or has provided such significant encouragement, either 
overt or covert, that the choice must in law be deemed to be that of 
the State.'' \27\ And in Norwood v. Harrison (1973), an Equal 
Protection Clause case, the Court viewed it as ``axiomatic that a state 
may not induce, encourage or promote private persons to accomplish what 
it is constitutionally forbidden to accomplish.'' \28\
---------------------------------------------------------------------------
    \26\ United States v. Folad, 877 F.3d 250, 253 (6th Cir. 2017) 
(emphasis added). See also United States v. Garlock, 19 F.3d 441, 443-
444 (8th Cir. 1994).
    \27\ 457 U.S. 991, 1004 (1982). See also Fidelity Financial Corp. 
v. Federal Home Loan Bank of San Francisco, 792 F.2d 1432, 1435 (9th 
Cir. 1986) (emphasis added).
    \28\ 413 U.S. 455, 465 (1973) (emphasis added).
---------------------------------------------------------------------------
               D. Potential Limits: Systemic Cooperation
    Might there be a difference between occasional one-off 
conversations and systematic programs? To be sure, when it comes to 
coercive threats aimed at suppressing speech, both the ad hoc and 
systematic demands are unconstitutional.\29\ Likewise, the cases 
involving government encouragement of searches by private parties find 
even ad hoc demands unconstitutional.\30\
---------------------------------------------------------------------------
    \29\ See Fagundes, supra note 14, at Part II.B.
    \30\ See id. at Part IV.A.
---------------------------------------------------------------------------
    But if courts do conclude that ad hoc requests to remove or block 
speech are constitutional, perhaps some line should still be drawn 
between those requests and systematic encouragement of such removing or 
blocking. This appears to be what the Fifth Circuit concluded in 
Missouri v. Biden, when it found that the government's speech was 
impermissible ``significant encouragement'' of speech restriction by 
platforms, even apart from the coercion argument:

        The officials had consistent and consequential interaction with 
        the platforms and constantly monitored their moderation 
        activities. In doing so, they repeatedly communicated their 
        concerns, thoughts, and desires to the platforms. The platforms 
        responded with cooperation--they invited the officials to 
        meetings, roundups, and policy discussions. And, more 
        importantly, they complied with the officials' requests, 
        including making changes to their policies. . . .

        When the platforms' policies were not performing to the 
        officials' liking, they pressed for more, persistently asking 
        what ``interventions'' were being taken, ``how much content 
        [was] being demoted,'' and why certain posts were not being 
        removed. Eventually, the officials pressed for outright change 
        to the platforms' moderation policies Beyond that, they 
        relentlessly asked the platforms to remove content, even giving 
        reasons as to why such content should be taken down. They also 
        followed up to ensure compliance and, when met with a response, 
        asked how the internal decision was made. . . .

        Consequently, it is apparent that the officials exercised 
        meaningful control--via changes to the platforms' independent 
        processes--over the platforms' moderation decisions. By pushing 
        changes to the platforms' policies through their expansive 
        relationship with and informal oversight over the platforms, 
        the officials imparted a lasting influence on the platforms' 
        moderation decisions without the need for any further input. In 
        doing so, the officials ensured that any moderation decisions 
        were not made in accordance with independent judgments guided 
        by independent standards. Instead, they were encouraged by the 
        officials' imposed standards.

        In sum, we find that the White House officials, in conjunction 
        with the Surgeon General's office, coerced and significantly 
        encouraged the platforms to moderate content. As a result, the 
        platforms' actions ``must in law be deemed to be that of the 
        State.'' \31\
---------------------------------------------------------------------------
    \31\ 83 F.4th 350, 387 (5th Cir. 2023).

    Indeed, when it came to requests for removal made by the Centers 
for Disease Control and Prevention, the Fifth Circuit concluded that 
the requests were not coercive, but still constituted unconstitutional 
---------------------------------------------------------------------------
significant encouragement:

        [T]he CDC was entangled in the platforms' decision-making 
        processes. The CDC's relationship with the platforms began by 
        defining--in ``Be On the Lookout'' meetings--what was (and was 
        not) ``misinformation'' for the platforms. Specifically, CDC 
        officials issued ``advisories'' to the platforms warning them 
        about misinformation ``hot topics'' to be wary of. From there, 
        CDC officials instructed the platforms to label disfavored 
        posts with ``contextual information,'' and asked for 
        ``amplification'' of approved content. That led to CDC 
        officials becoming intimately involved in the various 
        platforms' day-to-day moderation decisions. For example, they 
        communicated about how a platform's ``moderation team'' reached 
        a certain decision, how it was ``approach[ing] adding labels'' 
        to particular content, and how it was deploying manpower. 
        Consequently, the CDC garnered an extensive relationship with 
        the platforms.

        From that relationship, the CDC, through authoritative 
        guidance, directed changes to the platforms' moderation 
        policies. . . . [The platforms] adopted rule changes meant to 
        implement the CDC's guidance. . . . Thus, the resulting content 
        moderation, ``while not compelled by the state, was so 
        significantly encouraged, both overtly and covertly'' by CDC 
        officials that those decisions ``must in law be deemed to be 
        that of the state.'' \32\
---------------------------------------------------------------------------
    \32\ Id. at 390.

    And the court held the same as to CISA requests.\33\
---------------------------------------------------------------------------
    \33\ Id. at 391.
---------------------------------------------------------------------------
    As noted above, the Supreme Court reversed this Fifth Circuit 
decision on procedural grounds and cast some doubt on the factual 
findings on which the Fifth Circuit relied.\34\ But the Fifth Circuit's 
legal analysis as to substantial encouragement and systematic 
entanglement may still offer a persuasive precedent.
---------------------------------------------------------------------------
    \34\ See 603 U.S. at 60 n.4.
---------------------------------------------------------------------------
    Of course, distinguishing ``consistent and consequential 
interaction'' from mere occasional interaction--such as the examples of 
constitutionally permissible requests given above--can be difficult. 
Still, constitutional law does sometimes draw such distinctions between 
occasional action and systemic action. One analogy, though distant, 
might be how the law sometimes treats administrative searches.
    Courts have upheld various kinds of searches--even ones that lack a 
warrant, probable cause, or both--on the grounds that they are targeted 
at specific public safety concerns rather than at broad law 
enforcement. Airport searches of luggage, aimed at detecting weapons, 
are one example, as the Ninth Circuit discussed in detail in United 
States v. $124,570 U.S. Currency (1989).\35\
---------------------------------------------------------------------------
    \35\ 873 F.2d 1240, 1244-45 (9th Cir. 1989).
---------------------------------------------------------------------------
    Now say that Transportation Security Administration agents, U.S. 
government employees following their normal duty to search for weapons, 
spot a suspicious amount of cash or drugs. They then alert the police 
who use this information as part of the probable cause needed to 
justify a search. That is constitutional.\36\ TSA agents are free to 
``report information pertaining to criminal activity, as would any 
citizen.'' \37\
---------------------------------------------------------------------------
    \36\ See id. at 1247 n.7 (approvingly describing United States v. 
Canada, 527 F.2d 1374, 1376, 1378-79 (9th Cir. 1975)).
    \37\ Id.
---------------------------------------------------------------------------
    So far, so good. But say that the Drug Enforcement Administration 
comes up with a systematic program to encourage TSA agents to search 
not just for weapons, the rationale that led airport searches to be 
upheld in the first place, but also for drugs or cash. The Ninth 
Circuit held that this would be going too far:

        We see the matter as materially different where the 
        communication [about the drugs or money that the TSA agent 
        found] is undertaken pursuant to an established relationship, 
        fostered by official policy, even more so where the 
        communication is nurtured by payment of monetary rewards.\38\
---------------------------------------------------------------------------
    \38\ Id.

    Even if ad hoc reporting by TSA agents to the police of things 
other than weapons is permissible under the Fourth Amendment, a system 
set up to encourage such reporting is not. ``The line we draw is a fine 
one but, we believe, one that has constitutional significance.'' \39\
---------------------------------------------------------------------------
    \39\ Id.
---------------------------------------------------------------------------
    Or consider sobriety checkpoints. The Court has upheld them as 
permissible administrative seizures because they are aimed at 
protecting safety on the very roads that are being temporarily 
blocked.\40\ Yet the Court has held that the government may not set up 
drug trafficking checkpoints aimed at finding drug dealers.\41\ The 
difference in these cases, the Court held, stems from the ``difference 
in the Fourth Amendment significance of highway safety interests and 
the general interest in crime control.'' \42\
---------------------------------------------------------------------------
    \40\ Michigan v. Sitz, 496 U.S. 444 (1990).
    \41\ City of Indianapolis v. Edmond, 531 U.S. 32 (2000).
    \42\ Id. at 40.
---------------------------------------------------------------------------
    Now, if officers conducting sobriety checkpoints happen to see 
evidence of crime in plain sight--blood on the seat, an illegally 
carried gun, or, for that matter, drugs--they are free to keep 
detaining the driver and search further, based on this newly discovered 
probable cause.\43\ But say that the checkpoint is deliberately set up 
as a systematic way of searching for drugs or for other contraband. 
That would trigger additional Fourth Amendment scrutiny: ad hoc 
observation of evidence of crime, in the course of a valid 
administrative seizure (valid because the seizure is part of a drunk 
driving checkpoint, rather than a drug checkpoint or a general law 
enforcement checkpoint), may become unconstitutional if it happens in 
the course of a systematic program of search for evidence of crime.\44\
---------------------------------------------------------------------------
    \43\ See Texas v. Brown, 460 U.S. 730, 744 (1983) (plurality 
opinion); id. at 746 (Powell, J., concurring in the judgment); People 
v. Edwards, 101 A.D.3d 1643, 1644 (2012).
    \44\ I borrow this from United States v. Soyland, 3 F.3d 1312, 1317 
(9th Cir. 1993).
---------------------------------------------------------------------------
    I should stress again that these analogies are imperfect. Among 
other differences, they involve the Fourth Amendment and not the First, 
and concern attempts to systematically encourage certain action by 
government employees and not by private parties.
    But my point here is that they offer some support for the view that 
even if some actions are not subject to constitutional scrutiny when 
done on a one-off basis, they may become unconstitutional when done 
systematically. In the Fourth Amendment context, systematizing 
permissible ad hoc searches into ``an established relationship, 
fostered by official policy'' increases the threat of undue government 
intrusion on privacy, enough to change the Fourth Amendment analysis. 
Perhaps systematizing permissible ad hoc requests not to publish 
something (or to block or remove users' publications) into a similar 
official established relationship may likewise increase the threat of 
undue government interference with public debate to the point that 
First Amendment scrutiny would be required.
                  III. Reason for Congressional Action
    To be sure, courts may be reluctant to try to draw lines between 
permissible persuasion and excessively systematized persuasion. They 
might conclude that government attempts to persuade entities to 
restrict speech just aren't First Amendment violations, so long as they 
fall short of coercion.
    At the same time, even if the merger of government and social media 
platform power aimed at setting up a system for blocking, deleting, or 
otherwise deplatforming user posts isn't unconstitutional, it may be 
bad for democracy. At least, it may be the sort of thing that ought to 
be done with public scrutiny, rather than behind closed doors.
    And Congress may be able to draw lines that courts might be 
reluctant to draw. Indeed, the Committee's proposals seem to be 
promising ideas:

   Create transparency around Federal agency communication with 
        private entities on issues that may affect American speech.

   Produce guidelines that clearly restrict government 
        officials from influencing social media platforms' content 
        moderation decisions of constitutionally protected speech.

   Establish a reporting mechanism to allow platforms to report 
        if they think they may be experiencing government jawboning 
        efforts of censorship or content moderation.

   Before contemplating new Federal regulation, enact 
        guardrails that preclude existing Federal AI pro-grams, such as 
        the NAIRR and the Center for AI Standards and Innovation 
        (CAISI) (formerly known as the AI Safety Institute) from 
        curtailing speech in the name of addressing harms.\45\
---------------------------------------------------------------------------
    \45\ See The Mechanics of Government Censorship 35 (2025).

    Any such proposals would of course have to be carefully crafted, 
and would need to be attentive to how, for instance, we may want to 
expect different things from AI platforms than from social media 
platforms. But it's good that the Committee is considering what 
Congress can do here, rather than just relying entirely on courts.
    Indeed, such new statutes would be like other Federal statutes in 
which Congress has provided more protection for constitutional values 
than the courts have expressly held is required. For instance, Congress 
has chosen to provide extra protection for religious freedom through 
the Religious Freedom Restoration Act and the Religious Land Use and 
Institutionalized Persons Act. It has chosen to provide extra 
protection for free press through the Privacy Protection Act of 1980, 
which limits searches and seizures of journalists' notes and work 
product. It has chosen to provide extra protection for Fourth Amendment 
values through statutes such as the Stored Communications Act and the 
Electronic Communications Privacy Act. Likewise, Congress may wisely 
choose to provide extra protection against government jawboning for 
ordinary citizens' free speech and free press interests as well.
    The Internet has democratized speech, restricted the power of one 
set of intermediaries (traditional media), and empowered a new set 
(social media platforms). In the process, it has made the latter 
tempting targets both for government coercion and government 
persuasion. Congress should turn its attention to whether government 
jawboning, even when constitutionally permissible, unduly risks 
increasing government power and undermining public debate.
            Sincerely,
                                             Eugene Volokh,
                                    Thomas M. Siebel Senior Fellow,
                               Hoover Institution, Stanford University.
          Gary T. Schwartz Distinguished Professor of Law Emeritus,
                                                    UCLA School of Law.

    Senator Schmitt. Thank you very much.
    We will now recognize Mr. Alex Berenson to deliver his 
opening statement.

 STATEMENT OF ALEX BERENSON, INDEPENDENT JOURNALIST AND AUTHOR

    Mr. Berenson. Senator Schmitt, Committee Members, thank you 
for giving me the chance to speak on this crucial topic.
    On October 28--on August 28, 2021, Twitter, as it was then 
called, permanently suspended my account, supposedly for 
violating its COVID-19 Misinformation Rules. The ban deprived 
me of my largest and most vital platform for my journalism at a 
time when many Americans were eager to hear what I had to say 
about COVID and the mRNA vaccines and viewed what I wrote 
millions of times a day.
    Twitter's decision was no accident. It came after a 
deliberate and relentless campaign by the Biden administration 
as well as at least one senior Pfizer board member to violate 
my First Amendment Rights.
    Led by Andrew M. Slavitt, an official in the Biden White 
House, the administration began pressuring Twitter to silence 
me almost as soon as President Biden took office with both 
public and private attacks on my reporting. Frontline and 
senior Twitter employees viewed what was happening to me with 
dismay.
    Going back to 2020, the company had previously defended my 
right to speak as third parties demanded I be censored because 
Twitter believed that it should be a place where free speech 
and debate were encouraged.
    Ultimately, at the time of my suspension, Twitter's top 
executives, including then Chief Executive Jack Dorsey, 
secretly believed the company should not have suspended me. But 
the Twitter lobbyist who faced the Biden administration's 
pressure most directly went around them to orchestrate my ban.
    In the words he wrote to another Twitter official just days 
before he silenced me, this lobbyist hoped, ``To keep the 
target off our back'', none of this is speculation.
    Thanks to internal e-mails and other documents that Twitter 
turned over to me before Elon Musk took over, and more 
documents that Musk voluntarily and graciously turned over 
after he bought the company, I have hard proof of everything I 
have just told you.
    In fact, after I sued Twitter in 2021, in December 2021, 
over the ban, the company admitted I had not broken its rules 
and that my tweets, quote, ``Should not have led to his 
suspension''--``my suspension''. The company even reinstated me 
in July 2022. Again, that is before Elon bought Twitter.
    By then, though, I had already suffered and so had a lot of 
people who were depending on my reporting to help them think 
about COVID vaccines and COVID lockdowns. In losing my access 
to Twitter, I lost my best chance to offer Americans my 
dissenting views on the Biden administration's COVID vaccine 
mandates, mandates that the Supreme Court would later strike 
down.
    Federal District Judge Jessica G.L. Clarke laid out all 
these facts in two rulings she made this year on a 2023 lawsuit 
I brought against the Biden administration and senior officials 
at Pfizer for its censorship--for their censorship.
    In fact, in a ruling just last week, Clarke noted that, 
``On the merits, the Federal Government has now conceded my 
claim that the Biden administration unconstitutionally violated 
my First Amendment Rights in 2021''. Yet, in the same ruling, 
Clarke still dismissed my lawsuit. That may sound impossible. A 
Federal judge agreed my constitutional rights had apparently 
been violated, yet said my lawsuit over the violation could not 
move forward.
    But it is true. The Supreme Court has made it essentially 
impossible for me or anyone to win monetary damages for 
violations of their First Amendment Rights by the Federal 
Government. As the law now stands, Federal officials can run 
censorship campaigns, like the Biden administration carried 
out--like the one the Biden administration carried out against 
me, with impunity. At worst, they may face an injunction, but 
they will never have to pay for doing so for violating our most 
basic right, the right to speak freely.
    So it is open season for government censorship. This 
loophole is even more expansive and dangerous when it comes to 
Federal efforts to jawbone, pressure, or outright threaten 
third parties like Twitter into silencing the speech of their 
users, employees, or business partners. That is true whether 
these third parties are legacy media companies, news social 
media giants, or other types of businesses.
    As a practical matter, users are generally not privy to the 
communications between Federal officials and the companies, so 
they have no way of proving the pressure existed, or that it 
led to their censorship. My case is exceptional because of the 
documents I have proving my rights were violated. Yet even so I 
have been unable to obtain a remedy so far. And expecting 
companies to resist censorship on behalf of their users or 
business partners is unrealistic.
    My case, as well as documents the House has unearthed in 
its own censorship investigation shows social media companies 
dislike the Biden administration's efforts to force them to 
censor users, yet, they had many other interests before the 
Federal Government. They viewed sacrificing speech as the price 
they had to pay to stay in the administration's good graces.
    Every company will face this calculus, whether it is a 
Democrat or Republican, in the White House. And social media 
companies are really the most important way that independent 
Americans, that citizens can get their speech out into the 
marketplace of debate. That is why there is so much pressure on 
them.
    The truth is that as the law now stands, Federal officials 
have every reason to believe they can coerce private third 
parties to suppress speech. This is a powerful loophole that is 
no doubt enticing to politicians and officials of both parties. 
But it is wrong. Whether it affects Republicans or Democrats, 
journalists or comedians, conservatives, or liberals, or 
independents, and whether it goes by jawboning, coercion, 
pressure, or threats, this kind of censorship is wrong.
    And this committee has the chance to begin the process of 
fixing that wrong. I urge you to take it.
    [The prepared statement of Mr. Berneson follows:]

 Prepared Statement of Alex Berenson, Independent Journalist and Author
    Chairman Cruz, committee members, thank you for giving me the 
chance to speak on this crucial topic.
    On Aug. 28, 2021, Twitter (as it was then called) permanently 
suspended my account, supposedly for violating its ``COVID-19 
misinformation rules.'' The ban deprived me of the largest and most 
vital platform for my journalism--at a time when many Americans were 
eager to hear what I had to say about COVID and the mRNA vaccines and 
viewed what I wrote millions of times a day.
    But Twitter's decision was no accident. It came after a deliberate 
and relentless campaign by the Biden Administration (as well as at 
least one senior Pfizer board member) to violate my First Amendment 
rights. Led by Andrew M. Slavitt, an official in the Biden White House, 
the administration began pressuring Twitter to silence me almost as 
soon as President Biden took office, with both public and private 
attacks on my reporting.
    Both frontline and senior Twitter employees viewed what was 
happening to me with dismay. Going back to 2020, the company previously 
defended my right to speak as third parties demanded I be censored. 
Ultimately, Twitter's top executives, including then-chief executive 
Jack Dorsey, secretly believed the company should not have suspended 
me. But the Twitter lobbyist who faced the Biden Administration's 
pressure most directly went around them to orchestrate my ban. In the 
words he wrote to another Twitter official just days before he silenced 
me, the lobbyist hoped ``to keep the [White House] target off our 
back.''
    None of this is speculation. Thanks to internal e-mails and other 
documents that Twitter provided to me before Elon Musk took over--and 
more documents that Musk graciously and voluntarily turned over after 
he bought the company--I have hard proof of everything I've just told 
you. In fact, after I sued Twitter in December 2021 over the ban, the 
company admitted I had not broken its rules and ``Mr. Berenson's Tweets 
should not have led to his suspension.''
    The company even reinstated me in July 2022--again, before Musk 
bought Twitter. By then, though, the damage had already been done. In 
losing my access to Twitter, I lost my best chance to offer Americans 
my dissenting views on the Biden Administration's COVID vaccine 
mandates, mandates the Supreme Court would strike down.
    Federal District Judge Jessica G.L. Clarke laid out all these facts 
in two rulings she made this year on a 2023 lawsuit I brought against 
the Biden Administration and senior officials at Pfizer for its 
censorship. In fact, in a ruling just last week, Clarke noted that ``on 
the merits,'' the federal government has now conceded my claim the 
Biden Administration unconstitutionally violated my First Amendment 
rights in 2021.
    Yet, in the same ruling, Clarke still dismissed my lawsuit.
    This may sound impossible--a Federal judge agreed my Constitutional 
rights had apparently been violated, yet said my lawsuit over the 
violation could not move forward. Yet it's true.
    Why?
    Because the Supreme Court has made it impossible for me, or anyone, 
to win monetary damages for violations of their First Amendment rights 
by the Federal government. In fact, as the law now stands, Federal 
officials can run censorship campaigns like the one the Biden 
Administration carried out against me with near-impunity. At worst, 
they may face a judicial injunction telling them to stop violating the 
First Amendment. But neither the officials individually nor the 
government as a whole face any risk that they may have to pay for doing 
so--for violating Americans' most basic Constitutional right, the right 
to speak freely.
    It's open season for government censorship.
    This loophole is even more expansive, and thus dangerous, when it 
comes to Federal efforts to ``jawbone,'' pressure, or outright threaten 
third parties like Twitter into silencing the speech of their users, 
employees, or business partners. That's true whether those third-
parties are legacy media companies, new social media giants, or other 
kinds of businesses.
    Why? First, as a practical matter, users are generally not privy to 
the communications between Federal officials and the companies, so they 
have no way of proving the pressure existed or that it led to their 
censorship. My case is exceptional because of the documents I have 
found proving that my rights were violated--yet even so, I have been 
unable to obtain a remedy so far.
    Second, expecting the companies to resist censorship on behalf of 
their users or business partners is unrealistic. My case, as well as 
documents from Facebook/Meta and other social media companies that the 
Select Subcommittee on the Weaponization of the Federal Government has 
unearthed in its own censorship investigation, shows that social media 
companies disliked the Biden Administration's efforts to force them to 
censor users.
    Yet they had many other interests before the Federal government. 
They viewed having to sacrifice speech from some users as the price 
they had to pay to stay in the administration's good graces. Every 
company faces this calculus, whether a Democrat or Republican is in the 
White House.
    Yet jawboning of social media companies, in particular, is a more 
successful censorship strategy than ever before. These outlets are now 
the most important way for individuals to push their ideas into the 
marketplace of debate. I saw this firsthand in 2020 and 2021 (and still 
do). Twitter gave me a megaphone I would not otherwise have had, which 
is why the Biden Administration was so desperate to take it from me.
    In 2024, the Supreme Court found that ``a government official 
cannot do indirectly what she is barred from doing directly: A 
government official cannot coerce a private party to punish or suppress 
disfavored speech on her behalf.'' But that case, NRA v Vullo, applied 
to state government officials--New York state's insurance commissioner, 
to be precise.
    The truth is that as the law now stands, Federal officials have 
every reason to believe they can coerce private third parties to 
suppress speech without facing any sanction. And following the success 
of the Biden Administration's efforts against me and other users, they 
have every reason to believe those efforts will succeed.
    This is a powerful loophole that is no doubt enticing to 
politicians and officials of both parties. But it is wrong. Whether it 
affects Republicans or Democrats, journalists or comedians, 
conservatives or liberals or independents--and whether it goes by 
``jawboning,'' ``coercion,'' ``pressure,'' or ``threats,'' this kind of 
censorship is wrong. Only two institutions have the power to fix it--
Congress and the Supreme Court.
    But the Supreme Court has until now declined to act, by extending 
the right to money damages to First Amendment claims.
    This committee has a chance to begin the process of doing so--to 
take the first step helping Congress protect our vital Constitutional 
rights from censorious Federal officials. I urge you to take it.
    Again, thank you for giving me the chance to tell you about my case 
and my censorship. I view the protection of free speech as a bipartisan 
issue, and this issue as one that will hopefully have a bipartisan 
solution. I am happy to take any questions.

    Senator Schmitt. Thank you.
    We will now recognize Sean Davis to deliver his opening 
statement.

     STATEMENT OF SEAN DAVIS, CHIEF EXECUTIVE OFFICER, THE 
                           FEDERALIST

    Mr. Davis. It begins with censorship, it moves to the 
destruction of statues and monuments, and it ends with the 
murder of people. It begins with censorship, it moves to the 
destruction of statues and monuments, and it ends with the 
murder of people.
    The drive to silent speech does not end at a podium's edge 
or at the four corners of a page, it always advances toward the 
violent elimination of speakers. And that is because the 
authoritarian impulse to silent speech is driven by a 
totalitarian desire to seize total power by any means 
necessary, up to and including the murder of one's political 
opponents.
    This dynamic was made clear on a Tuesday afternoon in Utah 
last month when my friend, Charlie Kirk, was assassinated in 
broad daylight by a left-wing transgender ideologue who is 
enraged by Charlie's clear understanding and teaching that God 
created us male and female. That boys cannot become girls and 
girls cannot become boys. Charlie was murdered by this left-
wing assassin who had been radicalized by demonic transgender 
ideology because he was one of the most bold and effective 
speakers in the country opposed to this evil ideology.
    Rather than see a nation unite against terroristic violence 
designed to permanently silence speech, we actually saw the 
opposite. We witnessed people praising the murder of Charlie. 
We witnessed people thanking his assassin. We even witnessed 
members of the U.S. Congress all but say that Charlie deserved 
it.
    That is not the only recent example. The Democratic 
candidate for Attorney General in Virginia was revealed last 
week to have called for the murder of one of his political 
opponents. Even worse, he also said he wanted his opponent to 
witness the murder of his own children, to watch them die in 
their mother's arms. Why? To make him feel pain for having 
different political opinions.
    How many here today condemned that insanity or publicly 
recognized that someone with such a broken moral compass is 
simply unqualified to be a state's top law enforcement officer? 
We have heard the tired cliche that riots are the language of 
the unheard. But the reality is that violence is the language 
of the unhinged and far too many people in this room are fluent 
in it.
    My name is Sean Davis and I am the CEO and Co-Founder of 
The Federalist, a conservative digital media company that 
focuses on politics, culture, and religion. I am also a victim 
of illegal and unconstitutional censorship. My company, my 
colleagues, and I have been the targets of a coordinated and 
global multiyear censorship campaign.
    In 2020, a foreign government connected outfit in the UK 
colluded with Google to demonetize The Federalist, our crime, 
we published an article in the summer of 2020 entitled, ``The 
Media Are Lying to You About Everything, Including the Riots''.
    Later that year, in the midst of a close and heated 
Presidential election campaign, government-funded efforts in 
the U.S. repeatedly censored Mollie Hemingway, The Federalist 
Editor-in-Chief and a New York Times bestselling author who is 
here behind me today, and me because of our election reporting 
and commentary. I was censored for posting a screenshot of and 
a link to a Pennsylvania Supreme Court decision requiring mail-
in ballots received after election day and lacking a postmark 
to be counted and presumed as valid votes.
    Mollie was censored for posting a link to an article The 
Federalist published. The headline of that article, ``America 
Won't Trust Elections Until the Voter Fraud Is Investigated.''
    But the censorship did not stop there. We were also 
targeted for bankruptcy and destruction by the U.S. State 
Department and its Global Engagement Center, or GEC. Despite 
the fact that GEC was explicitly prohibited by both the U.S. 
Constitution via the First Amendment and its authorizing 
statute from targeting domestic speech, it nonetheless sought 
to drive us out of business by funding, developing, and 
distributing technologies and tools to reduce our reach, by 
bullying advertisers into blacklisting us, and many other 
conservative outlets, and by coercing big tech companies like 
Facebook, Google, and Twitter to throttle access to our 
content.
    In essence, our own government secretly and without any due 
process, charged us with thought crimes, convicted us, and 
sentenced The Federalist to death. The censorship efforts our 
government funded with our money are still being wielded 
against us today.
    I am here today to testify about the unconstitutional and 
illegal censorship of my company and my colleagues. But I am 
also here to help you understand the real-world consequences in 
flesh and in blood of the drive to silence your political 
opposition.
    It does not stop at the page's end. The effort to censor 
and silence political opposition is not the final step in the 
effort to usher in tyranny and authoritarianism. It begins with 
censorship. It moves to the destruction of statues and 
monuments, and it ends with the murder of people. And it has to 
stop. Thank you.
    [The prepared statement of Mr. Davis follows:]

  Prepared Statement of Sean Davis, CEO and Co-Founder, The Federalist
    Chairman Cruz, Ranking Member Cantwell, and members of the 
committee, thank you for inviting me to testify on behalf of First 
Amendment speech and press rights and against authoritarian censorship 
designed to shut down the free speech rights of American citizens.
    My name is Sean Davis, and I am the CEO and co-founder of The 
Federalist, a conservative digital media company focused on politics, 
culture, and religion. I am a Christian, a conservative, and a 
political commentator and reporter. I am also the victim of illegal and 
unconstitutional censorship by my government which was targeted at my 
publication, my publication, and me personally.
    The First Amendment affirms and protects five God-given rights: 
free speech, religion, press, assembly, and petition. In my capacity as 
the publisher of a major national media outlet which produces news and 
opinion, an infringement on or abridgement of any one of those five 
rights can be cataclysmic.
    Unfortunately, my publication, our writers, and I were all directly 
targeted for destruction by my own government, using my tax dollars. 
Even worse, much of the targeting was done in secret, by individuals 
and institutions who were desperate to hide their illegal and 
unconstitutional actions against us. This long-running conspiracy to 
deprive us of our God-given First Amendment rights is illegal, 
unconstitutional, and unconscionable. Sadly, many senators who sit on 
this committee either refused to condemn and fight these censorship 
efforts, or outright supported them.
    In the summer of 2020, at the behest of foreign government-
connected organizations, Google attempted to demonetize The Federalist 
for the apparent crime of criticizing American government response to 
and media coverage of COVID-19 and the violent Black Lives Matter (BLM) 
riots that raged throughout the country. The apparent article that 
triggered this outrageous attack on us and our First Amendment rights 
was entitled, ``The Media Are Lying To You About Everything, Including 
The Riots.''
    This was all orchestrated secretly behind closed doors between a 
foreign NBC News cell and corrupt Google executives, despite the fact 
that we had broken zero rules. But that was only the beginning.
    Unbeknownst to us at the time, a government department called the 
Cybersecurity and Infrastructure Security Agency (CISA) was also 
directing and funding censorship efforts against my colleagues and me 
because of our reporting on unprecedented new election laws rammed 
through ahead of the 2020 election. This agency is supposed to prevent 
attacks on American infrastructure, but at some point its leaders 
apparently decided that its real objective was to censor American 
citizens and journalists for criticizing their own government.
    My colleagues and I were deliberately singled out for censorship 
because our own government decided our rights as citizens and members 
of the news media needed to be crushed. The agency and its partners 
used a ticketing system to flag and report social media posts that it 
wanted to be eliminated and funded efforts to badger and threaten tech 
companies, many of which had effective monopolies over online content, 
to delete social posts that the government and its partners found 
inconvenient.
    For those who know me or follow me on social media, I can be 
opinionated and provocative. But in this particular case, it wasn't 
even one of my spicier tweets that attracted the ire of Orwellian 
government censors. In a tweet targeted for censorship, I posted a 
screenshot of and a link to a Pennsylvania Supreme Court decision which 
stated that mail-in ballots received after the election and containing 
no postmark still had to be presumed as cast on-time, and counted. 
Anyone who understands basic logic can see the problems with such a 
declaration: ballots cast and mailed long after the election, 
potentially even after preliminary results were known, would still have 
to be counted, creating huge incentives to flood the system with late, 
invalid ballots.
    My tweet with the link to and screenshot of that Pennsylvania 
Supreme Court decision was censored by Twitter, and it was done so at 
the direct demand of a U.S. Federal government-sponsored censorship 
consortium. Another one of my tweets, in which I alleged that the best 
evidence that the 2020 election was being rigged was the fact that 
tweets stating the election was being rigged were being censored, was 
censored. Another ticket demanding censorship of me stated, ``[S]ame 
guy (sean davis) continues to post about this. has spread to thousands 
on [Facebook] because of Federalist article[.]''
    According to JIRA ticket data obtained and release by the House 
Judiciary Committee, at least 21 separate tickets were submitted to 
censor Twitter posts from me. Several of those tickets also demanded 
censorship by Facebook.
    Kafka-esque doesn't even begin to describe this madness.
    My colleague Mollie Hemingway, who wrote a national best-selling 
and rigorously researched and fact-checked book about 2020 election 
shenanigans, was also censored by Twitter at the demand of the Federal 
government and its partners. Multiple censorship tickets were submitted 
to shut down her social media presence. The most ridiculous example was 
a demand to censor a tweet from Mollie which contained a link to an 
article published by The Federalist. The headline of that article? 
``America won't trust elections until the voter fraud is 
investigated.''
    Imagine how deranged and authoritarian you must be to want to 
censor a post about how addressing voter fraud is key to ensuring 
election integrity.
    Though we noticed and wrote about that censorship at the time, we 
had no idea that it was our own government which funded and targeted 
our speech for censorship, nor did we understand how often we had been 
targeted, both personally and institutionally. It was only through 
dogged investigation and oversight from people like Rep. Jim Jordan and 
then-Missouri Attorney General and now-Sen. Eric Schmitt that the 
depths of the government scheming against us even began to be plumbed.
    Again, the censorship didn't stop there, and it didn't remain 
contained within CISA. We were also targeted for outright bankruptcy 
and destruction by the U.S. State Department and its Global Engagement 
Center (GEC). Despite the fact that GEC was explicitly prohibited by 
both the U.S. Constitution via the First Amendment and by the very 
statute which created and authorized the agency from targeting domestic 
speech, it nonetheless sought to drive us out of business by funding, 
developing, and distributing technologies and tools to reduce our 
reach, by bullying advertisers into blacklisting us and many other 
conservative outlets, and by coercing Big Tech companies like Facebook, 
Twitter, and Google to throttle access to our content. In essence, our 
own government secretly and without any due process charged us with 
thoughtcrimes, convicted us, and sentenced The Federalist to death.
    We survived, but just barely.
    Once the censorship-industrial complex injected its lies into the 
bloodstream of the body politic, the effects became endemic and 
permanent. To this day, we are still dealing with the effects of their 
blatantly illegal and unconstitutional censorship efforts. Although we 
sued in Federal court nearly two years ago, we are still awaiting 
relief. Although the President and Vice President of the United States 
admitted that these illegal censorships efforts were undertaken, we are 
still awaiting relief. And although the U.S. Secretary of State 
himself, whose agency targeted The Federalist, plainly admitted in our 
very pages that the State Department did exactly what we alleged, we 
are still awaiting relief. Some members of this committee have 
supported our efforts to vindicate our rights. Many, however, haven't 
said a word in our defense, a fact which suggests that defenses of 
media millionaires like Jimmy Kimmel are based more on partisanship 
than any sort of actual belief in free speech.
    And it is worth noting that unlike Mr. Kimmel, who is employed and 
distributed by a broadcaster who is required to abide by well-known 
rules as a condition of operating a monopoly on publicly owned 
airwaves--rules that were drafted and enacted by this very legislative 
body--my colleagues and I are independent journalists who operate 
online, far outside the regulatory purview of the Federal 
Communications Commission (FCC). FCC rules and regulations, which radio 
and television broadcasters like Mr. Kimmel are required to obey, do 
not apply to us. It also takes real chutzpah, in the aftermath of the 
assassination of Charlie Kirk--who was brutally murdered while 
peacefully debating a college student about transgender ideology--to 
try and make Jimmy Kimmel a free speech martyr just to cynically change 
the subject from yet another example of left-wing violence designed to 
permanently silence not just speech, but its speakers.
    As we noted in our complaint against the State Department, we are 
the victims of one of the most audacious, manipulative, secretive, and 
gravest abuses of First Amendment rights by the Federal government in 
American history.
    I have no doubt today that we will hear words like 
``disinformation,'' ``misinformation,'' and ``malinformation'' thrown 
around by politicians desperate to create a pretext for censoring 
speech and speakers they don't like. Make no mistake: these types of 
labels exist entirely to justify illegal and unconstitutional 
violations of the First Amendment rights of every American.
    Americans are allowed to say ridiculous things on the Internet. 
They are allowed to post things you don't think are true. They are 
allowed to publish things that are mean. They are allowed to be 
hateful. Politicians and government officials do not have the authority 
to bootstrap their way to censorship by baselessly throwing a ``Russian 
disinformation'' label on every post or news article they don't like. 
In fact, the more a particular politician dislikes a particular 
political statement, the more it is protected by the First Amendment. 
We don't really need laws to protect popular speech. It is the 
unpopular speech, the speech that criticizes government, that is most 
desperately in need of protection.
    It also is imperative that everyone lives under the exact same 
speech regime. A legal regime in which one party or one side of the 
political spectrum has free speech, while another is subjected to 
speech controls, is an abomination, and one that should not be 
tolerated. It is absurd to watch the government crack down on accurate 
reporting, like that of the New York Post, which was censored for 
reporting on Hunter Biden's laptop, and then watch publications that 
repeatedly published falsehood after falsehood not just escape 
scrutiny, but receive lucrative journalism prizes and rewards for their 
nonsense.
    I would prefer that everyone live under a legal regime that 
treasures and protects free speech and freedom of the press. In fact, I 
have fought for that for years. But I will not abide a system that 
illegally cracks down on conservative media while doing nothing to stem 
left-wing lies. Everyone should live under the same set of rules.
    The best antidote to speech you don't like is more speech. That is 
why the Founding Fathers drafted the Constitution and the Bill of 
Rights. They understood that a government could not purport to 
represent its people if it prohibited their rights to speech, assembly, 
religion, press, and petition. It is time to return to a world where we 
can say what we wish without fear of being censored, or deplatformed, 
or shot dead.
    If you woke up two weeks ago and suddenly decided you care about 
free speech, I invite you to prove it. I invite you to demonstrate to 
the world that your commitment to free speech is principled, rather 
than an attempt to change the subject because one of your famous 
millionaire friends on television received 1/1,000,000,000th of the 
treatment that conservatives have been subjected to for years. I invite 
you to condemn the nakedly illegal and unconstitutional censorship 
efforts of the last 5 years. I invite you to apologize for any past 
support of censorship. I invite you to finally stand up for speech you 
don't like from people you don't like. And I invite you to condemn any 
and all violence meant to permanently silence speech, and speakers, 
even if you hate them.
    Prove your commitment to the First Amendment is real by finally 
admitting to the censorship schemes many of you cheered, and working to 
make sure nothing like that ever happens again.

    Senator Schmitt. Thank you. We will now recognize Mr. Gene 
Kimmelman for his opening remarks.

  STATEMENT OF GENE KIMMELMAN, SENIOR FELLOW, TOBIN ECONOMIC 
                 POLICY CENTER, YALE UNIVERSITY

    Mr. Kimmelman. Thank you, Mr. Chairman, Senator Cantwell, 
Members of the Committee. It is an honor to appear before you 
today.
    So as we have experienced this explosion in digital 
technology which fundamentally is transforming our media 
landscape and information ecosystem, I think the fundamental 
principles that our democracy has always relied upon remain the 
same. First, we must prevent government from censoring 
protected speech as Mr. Volokh said. Second, we must also 
prevent media and information distribution platforms from 
concentrating enough power to block the competition and 
diversity that fuels open debate in our society.
    I am worried that the current FCC is heading down a 
dangerous path on both of these principles. Recent statements 
from Chairman Carr echoing the President threatening to revoke 
broadcast licenses for presenting content unfavorable to the 
administration has chilled protected speech, and the FCC's push 
to eliminate or relax broadcast ownership rules and to welcome 
consolidation in media threatened the independence and 
diversity of local media that are critical to an informed 
citizenry.
    Just consider we have pending before us the NextStar merger 
with TEGNA, combining broadcast--national broadcast companies 
with more than 250 broadcast stations. combining multiple 
broadcast licenses in the top markets that are the most popular 
broadcast television stations, and having ownership in two-
thirds of all markets, covering almost 80 percent of all 
households in the country, even though this appears to violate 
the limit Congress set at half that level Chairman Carr seems 
to be moving forward.
    And this is on the heels of Skye Dance backed by Oracle's 
owner, Mr. Larry Ellison, buying Paramount Global, CBS, now 
seeking to buy Warner Brothers, Discovery, more studios, more 
networks, cable channels, and Mr. Ellison appearing to pick up 
about a 20 percent stake in TikTok. And the FCC is also 
considering allowing companies to own multiple national 
networks.
    These deals, and certainly more to follow, likely threaten 
to build a form of private censorship through outsized media 
power. It is time to update the law and establish new 
guardrails to promote local, diverse, and independent media. 
The threat to democracy also comes from the dominant 
information distribution systems controlled by Google, Meta 
with Facebook, Instagram, WhatsApp, and Apple with its App 
Store.
    Here, the Trump administration has done an excellent job 
challenging these companies monopolistic behavior, continuing 
the antitrust enforcement from the Biden administration. 
However, antitrust is not enough to eliminate the enormous 
power of these text platforms. More needs to be done.
    Congress must give antitrust enforcers more tools to truly 
open up the tech information distribution platforms and modern 
media markets to robust competition. We need to reduce 
concentration of control in these markets. Private control that 
can censor just as the government can censor.
    In conclusion, I want to say it is really time for Congress 
to update the Communications Act, to jump in and put an end to 
the threat of the bullying that we are seeing from the FCC, 
which chills speech and eliminates open debate and information 
flow in our media. And it is time to stop media consolidation 
and monopolization that puts too much control over the 
marketplace of ideas into few hands.
    Thank you, Mr. Chair.
    [The prepared statement of Mr. Kimmelman follows:]

  Prepared Statement of Gene Kimmelman, Senior Fellow, Tobin Economic 
Policy Center, Yale University; Senior Fellow, Mossavar-Rahmani Center 
          for Business and Government, Harvard Kennedy School
    Democracy in the United States is built upon a foundation of 
constitutional speech protections plus a process of open debate and 
elections, fueled by independent and diverse media. I believe our 
democracy cannot survive unless we prevent government from coercing or 
suppressing protected speech. Nor can it survive without strong 
competition along independent and diversely owned information and media 
distribution platforms.
    A robust marketplace of ideas requires strong protection against 
both public interference in open debate and the exercise of private 
market power that distorts or blocks public discourse. I am concerned 
that recent statements and actions from government officials, like the 
Chairman of the Federal Communications Commission (FCC), appear 
designed to unduly pressure tech platforms and media distribution 
companies to favor certain speech and suppress the views of others. I 
am equally concerned that a wave of media consolidation driven by the 
current FCC's efforts to relax or eliminate ownership rules will 
concentrate local media power in the hands of a few national companies, 
reduce the diversity of national media players, and thereby empower a 
few media tycoons to distort the most popular sources of information in 
our society.
    While strong antitrust enforcement can play a critical role to 
prevent media monopolization or excessive concentration of ownership, 
it is not enough to ensure open debate through local and diverse 
players in the media ecosystem. The Trump Administration's antitrust 
enforcement cases (which build upon the work of the Biden 
Administration) against Google's, Meta's, and Apple's monopolization 
practices are precisely what is needed to break up or restrain tech 
platform practices that harm competition and impede the free flow of 
information.
    Although many of these cases are still pending, the recent Google 
search remedy decision illustrates how cautious courts are when 
confronted with a legitimate request to require asset divestitures or 
ban on payments that have been found by the courts to be illegal in 
nature. Courts seem reticent to upend business models, even in the face 
of blatantly illegal behavior. Furthermore, antitrust was never 
designed to directly promote democracy by maximizing diverse 
marketplace voices. Antitrust is a necessary but often insufficient 
tool to sustain local, diverse media.
    That is why Congress's decision to promote local and diverse media 
through communications policy has always been so important to our 
democracy. Obviously, the explosion of digital technology has 
dramatically changed the media landscape. However, a substantial 
portion of the public still relies upon local broadcast content, 
regardless of how the content is distributed, for their daily news and 
information. More importantly, these local media play a critical role 
in promoting open public debate at the key moments when we select our 
public representatives.
    I am therefore concerned that the FCC is heading down a very 
dangerous path by suggesting that diverse and locally controlled 
broadcast media may not matter anymore. It is also disconcerting to see 
a data gathering giant (Oracle) become financially intertwined with a 
national television network (Paramount/CBS) which is seeking to 
purchase a major studio and cable channels through Warner Bros 
Discovery while picking up a substantial ownership stake in TikTok. 
Such conglomeration involving major media companies threatens media 
diversity and will likely lead to further consolidation among other 
tech and media players.
    Now is the time for Congress to step in and update the 
Communications Act and expand antitrust tools that can pry open tech 
platforms and the emerging Artificial Intelligence (AI) market to 
increase competition. I believe technological changes have blurred the 
lines between broadcast, cable, streaming, website content, and user 
generated media like YouTube. Therefore, Congress needs to delineate 
and update public duties across all media. Congress should treat all 
forms of media power equally, and establish new standards for 
independent ownership and control that promote a robust marketplace of 
ideas. In addition dominant tech platforms must be prevented from 
discriminating against those dependent on information and services 
distributed over those platforms.
    Given that Google was not constrained by the Federal District Court 
from making unlimited payments to Apple, Samsung, Motorola, or the 
wireless phone carriers to promote their search and AI services, it is 
now imperative that Congress also established guardrails to ensure that 
neither Google nor anyone else can dominate the exploding AI 
marketplace.
    It is critical that we prevent both government and private players 
from impeding the free flow of ideas in our society. Our democracy 
cannot survive without robust media competition and open debate, 
especially involving public discourse about how we govern ourselves.

    Senator Schmitt. Thank you. Thank you for testimony.
    And I guess I will just start there with just a quick 
question. So Mr. Kimmelman, you are the CEO of a group called 
Public Knowledge; is that correct?
    Mr. Kimmelman. I was at one point, sir.
    Senator Schmitt. OK. When what years were you the CEO of 
Public Knowledge?
    Mr. Kimmelman. 2014 to 2019.
    Senator Schmitt. OK. Let us just take a DeLorean back in 
time to COVID era. Do you think it is appropriate for these, 
sort of, NGOs or non-profits to work hand-in-hand with 
government agencies to flag misinformation, or disinformation, 
or malinformation?
    Mr. Kimmelman. Mr. Chairman, I have worked with NGOs for 
many, many years, and I think it is appropriate on the left and 
the right for them to present ideas to the government, to the 
major players in the marketplace about their views, that 
certainly, that is what I was involved with.
    Senator Schmitt. Well, let me get more specific then. Do 
you think it is appropriate that the White House was working 
directly through a number of different agencies to work with 
the University of Washington and Stanford information to sort 
of outsource their censorship enterprise to find out what the 
posts that they did not like, and then work with--and then 
collude with at least, or coerce social media companies to 
punish those folks?
    Mr. Kimmelman. Well, Senator, I think it is--I have seen 
the government in many instances work with private 
contractors----
    Senator Schmitt. But I am asking--I am asking about this 
instance because it was not like a you know a galaxy far, far 
away, it was like a few years ago. Do you think that is 
appropriate?
    Mr. Kimmelman. Yes, I am not familiar with the details of 
what might or might not happen there.
    Senator Schmitt. But what about the scenario I just gave 
you though?
    Mr. Kimmelman. Working with a university to----
    Senator Schmitt. To flag misinformation so that the 
government then can coerce social media companies to throttle 
or to----
    Mr. Kimmelman. I never think government should coerce 
social media companies, so I cannot imagine----
    Senator Schmitt. OK.
    Mr. Kimmelman [continuing]. That that part of it as----
    Senator Schmitt. OK. Thank you.
    Mr. Davis, your testimony described how in the summer of 
2020 Google attempted to demonetize The Federalist following 
your critiques of violent Black Lives Matter riots. it is 
documented that the Center for Countering Digital Hate, the 
CCDH, specifically worked to demonetize The Federalists for 
these critiques. Could you just describe what tactics, 
specifically, were employed to do that?
    Mr. Davis. Yes, sir. Thank you for bringing that up. So I 
believe it was in July 2020, we started receiving e-mails from 
a NBC News reporter based out of the UK, I do not remember her 
name exactly, and they were almost taunting asking for comment: 
Hey, Federalist, how does it feel knowing Google is going to--
is about to demonetize you for hate speech, or something like 
that. I am paraphrasing.
    And this was news to us. We had not broken any rules. We 
had gotten no notifications of breaking rules that we had 
violated Google's terms and conditions, or AdSense's, or 
whatever. And so we started calling around to contacts at 
Google and learned that: Oh, yes, you are about to be 
demonetized because of hate speech was what we were told. We 
had, you know, racist, violent hate speech which was not true 
at all.
    And it was the CCDH who was working with this NBC News, I 
think it was called the Verification Unit at the time, they 
were working together and colluding with executives at Google, 
to this day I do not know who, to come in and secretly 
demonetize us. And what I found most offensive about it was 
they were all in on it. They had news articles ready to be 
written kind of crowing about how we got demonetized.
    We were able to fight back. We had a pretty robust response 
to that, and they ended up relenting. Largely, what was 
interesting was in that initial news article targeting us they 
had cited that news article, how the media are lying to you 
about literally everything including the riots. The NBC News 
ended up stealth editing that out, and they worked with Google 
to come up with a new rationale for demonetizing us, which was 
our comments were mean.
    We had an unmoderated comment section. So we ended up 
having to delete our comment section to avoid being demonetized 
by Google because a bunch of foreign-connected government 
outfits decided that they did not like what we were publishing.
    Senator Schmitt. OK. In limited time, I want to--Mr. 
Berenson, it is clear now that during the Biden administration, 
CISA, which is mentioned a lot in this report obviously, 
operated kind of a switch-boarding mechanism during this period 
flagging disfavored content from domestic sources for social 
media platforms. Based on what you have seen, how was CISA 
specifically doing this? What was the abuse really all about?
    Mr. Berenson. Well, again, I think you laid it out. You 
know, they redefined infrastructure so it was not actual 
physical infrastructure or software infrastructure it was 
things people were saying. And you know, there was a period 
very early in 2022 when they actually tried to redefine 
terrorism as quote/unquote ``misinformation'', there is a 
bulletin from February 2022 which I think DHS put out and then 
retracted under pressure.
    So you know, once you start saying that people's speech is 
terrorism, you are going down a bad path and I think--I do not 
think that is something that either party should do, honestly.
    Senator Schmitt. Thanks. Ranking Member Cantwell.
    Senator Cantwell. Thank you, Mr. Chairman. I am going to 
yield to my colleague for a second to make a statement, then I 
will finish with my questions.

               STATEMENT OF HON. AMY KLOBUCHAR, 
                  U.S. SENATOR FROM MINNESOTA

    Senator Klobuchar. Thank you. I will do my questions on the 
record because I have to leave, but I was not going to speak 
and I appreciate Senator Cantwell's willingness to let me say a 
few words here, given what happened in my state this summer.
    First of all, I think Mr. Kimmelman knows that I have been 
out front on monopoly issues, and antitrust, and making sure 
that we have true competition in the marketplace, working with 
Senator Cruz, and Senator Lee, and Senator Kennedy, and many 
others on that issue, and I continue to believe that it is a 
legitimate solution.
    Second, I think what happened with the Chair of the FCC was 
wrong in the last month. I appreciated Senator Cruz being out 
front on it. I truly do. And calling it out. And I am looking 
forward to that hearing to try to get some sense into what is 
going on there, with not just the Jimmy Kimmel moment, but many 
others.
    Third, I think that the AI piece of this, and I will ask 
some questions about this, but to me, it should not be that 
radical that we say number one that if speech is violent or it 
incites violence, that that is different than other kinds of 
speech, but that with these AI videos where you cannot even 
tell it is yourself or not, I had this experience at a hearing, 
that they could at least be labeled.
    It is always going to be litigation over whether something 
is the violent side, and the heat side, or whether it is the 
legally, constitutionally allowed speech like parody. But at 
the very least these videos should say something about prepared 
for by AI, or digitally created.
    I just happened to be late on CNN last night and Robin 
Williams' family was on one of the shows talking about how he 
is dead, and they have created AI videos that do not say 
digitally altered, that people think are real. So people should 
have the right over their own identity.
    And the last thing, when it comes to these horrific mass 
shootings and acts of violence, I have come to see them as all-
purpose haters, which is something that the FBI actually said, 
after the enunciation, church shooting in Minnesota, because 
that shooter actually hated President Trump in the manifesto, 
hated wokeness, hated Jews, hated Muslims, hated Hispanics, 
hated Blacks, and shot these two little kids, Fletcher and 
Harper, through stained-glass windows in a Catholic church.
    Then you go to the shooting of my dear friend, and I had a 
good discussion with FBI Director Patel about this in 
judiciary. He lost his friend Charlie Kirk and we mourn that. 
And we lost our friend Melissa Hortman.
    Now, that shooter literally had a manifesto or ramblings 
that targeted mostly, and in fact all Democratic office holders 
and he went to the houses of the people that he knew--that he 
knew the addresses, and the ones that he did not he was not 
able to go to.
    He went after law firms, businesses, went after planned 
parenthood, and then left a actual letter saying that he did it 
because he was supposed to assassinate me, which is on X about 
every 5 minutes with my name with ``assassination'', which I 
think is completely not a good idea for public safety, but I 
cannot get it off.
    So the point of all this is that to say it is one side or 
the another when you look at the Cato Institute Report that 
came out this year of this extremism and what is triggering 
these, basically, mad murderers to commit these acts, whether 
it is in the Michigan temple, or whether it is Charlie Kirk in 
Utah. I just do not think it is the right approach to be like 
it is one side or the other.
    These people have been targeted, in their heads, and they 
go out and create these mass crimes and it is on us to figure 
out what is triggering them and actually do something about it 
instead of playing the blame game.
    One of my answers is an assault weapon ban or at least 21 
years and under that would have helped in Uvalde, Buffalo, 
Parkland, doing something about this instead of just blaming 
each other. Thank you.
    Senator Schmitt. Thank you. Senator Fischer.

                STATEMENT OF HON. DEB FISCHER, 
                   U.S. SENATOR FROM NEBRASKA

    Senator Fischer. Thank you, Senator Schmitt.
    Mr. Davis, government censorship in the name of fact-
checking is an unacceptable trampling on our democratic values. 
Knowing what we know now, how should social media companies 
respond if the government comes to them to deplatform users 
based on their political opinions? What is your suggestion?
    Mr. Davis. That is a great question. Thank you for raising 
it. If I could wave a magic wand and create a solution or a 
response there, what I would say is anytime a government goes 
to a social media platform, Google, YouTube, Twitter, whatever, 
and they tell someone, you need to take this down because it is 
hate speech, or misinformation, or whatever fancy label they 
want to throw on speech they do not like, first off, those tech 
companies should tell them to take a hike. We do not censor 
anyone. We are a platform. we are not a content company.
    And then number two, I think they should have to disclose 
it to the public and the people who were targeted. I would love 
to have known in 2020 who was actually behind the censorship of 
me and my colleagues. We knew we were being censored because we 
watched it happen. We saw our posts disappear. We saw ourselves 
being shadow-banned. We did not actually know why.
    I would say to this day, we do not actually understand the 
full extent of the government effort to censor us. So I think 
there should be full disclosure following an absolute denial of 
any sort of censorship demands from government. it is totally 
inappropriate.
    Senator Fischer. Thank you. Mr. Berenson, I thank you for 
sharing your experience of being deplatformed by Twitter. it is 
a valuable story for us to hear. You spoke of a huge influence 
that you witnessed between Twitter and the White House at the 
time back in 2020. And you described your understanding that 
the company's lobbyist hoped to keep the White House target off 
their back. Can you explain, specifically, what your 
understanding of that target was? And are you aware of any 
specific threats that were made?
    Mr. Berenson. Sure. So in July 2021, as the Biden 
administration was preparing vaccine mandates, and that is sort 
of what you have to understand about the backdrop here, and 
they knew that those might be politically unpopular, they 
started pressuring the companies to deplatform people like me--
I mean, they have been doing this, but they upped the pressure. 
And that is when President Biden said that Facebook was quote/
unquote, ``Killing people'' by allowing people like me or RFK 
Jr. to speak.
    And you know, the biggest legal protection that social 
media companies have is what is called the Section 230, as I am 
sure you know, where they are essentially immune from lawsuits, 
from users over the decisions they make for content. So they 
have all the immunity of a traditional publisher to make 
decisions over what speech they want to carry, and so----
    Senator Fischer. Yes. But did the White House--do you have 
any of any kind of information or records? Did the White House 
specifically say what they would do to Twitter?
    Mr. Berenson. Well, so they specifically--well, they 
publicly said that they were going to reconsider Section 230. 
That was again in July. And they had privately said to Twitter 
in April, they had, based on Twitter's own records said a 
really--quote/unquote, ``A really hard question about why I was 
still being allowed to speak'', which in my--from my point of 
view, and my lawyer's point of view, that all by itself was a 
First Amendment violation, because it forced Twitter to start 
looking at me in a way that Twitter had not previously done. 
And that was in secret. And you know and I will say this I----
    Senator Fischer. And again, there was no transparency 
that----
    Mr. Berenson. No transparency----
    Senator Fischer.--as Mr. Davis spoke on.
    Mr. Berenson. Yes. So I mean, look, what I do not like what 
Brendan Carr did but he did it publicly and we can have a 
debate about it. What is really problematic is when the 
government goes in secret to these companies and targets 
individual users or individual categories of speech. And I 
think that that should not be allowed. I think that both 
parties should agree that that targeting an individual user, or 
an individual post, as you know, if it is legal, it is wrong.
    And nobody has ever said that I had said anything illegal, 
and actually I think most people now would agree that a lot of 
what I said was--has been confirmed. So I think that that is a 
pretty basic place to start.
    Senator Fischer. Thank you. Mr. Volokh, you mentioned a 
reporting mechanism that might be a promising idea for 
companies that think the government is coercing them. Can you 
describe to the Committee how such a mechanism might have 
prevented a situation that Mr. Berenson just described, and how 
would you structure that mechanism?
    Mr. Volokh. Sure. So this is a familiar line [no mic]--is 
the best disinfectant. There may in fact be certain kinds of 
requests to remove something that might be justifiable in 
certain situations, if they are not coercive, but they are 
just, kind of appealed to somebody's better instinct. Maybe, 
maybe not.
    But presumably it is something that members of this 
committee, that other Members of Congress might be interested 
in, that reporters for newspapers might say: Well, here is a 
list of all of these things that the government has been asking 
that people remove. Is it justifiable or not? Is it excessive? 
Does it show political bias? That is impossible to do if it is 
all essentially corporate secrets and government secrets.
    Senator Fischer. Is there, I am picking up on Senator 
Klobuchar's--I am over time. Can I finish? Thank you.
    Senator Klobuchar was saying, is you know, she is worried, 
as I think many of us are with AI and things that are happening 
there, and at least to get a label, at least to get a label. Do 
any of you know, are these social media companies, any of these 
companies capable of doing that to be able to identify when 
something has been tampered with, with AI, or if it is to 
totally false, to be able to do that?
    Mr. Volokh. So I think that that is a separate question but 
a very important question, there is a--what you are asking I 
think is the technical question, which is even if they were 
just to do it on their own, can they do it?
    Senator Fischer. And in that case----
    Mr. Volokh. So my understanding is that there are ways of 
determining that, they are hard to do at scale. So perhaps a 
forensic examiner might look at a video, but it does not mean 
that you can have an algorithm that will reliably do it, and 
there is going to be false positives and false negatives. There 
is also always going to be an arms race, right.
    If there is a better fake technology, better detector 
technology, better fake technology that evades the detector 
technology. I am not up on all the details, but my 
understanding is right now there is no guaranteed reliable 
mechanism of determining it all.
    Senator Fischer. Then maybe you get into the whole question 
also on, what is comedy, what is satire.
    Mr. Volokh. Yes.
    Senator Fischer. It opens up a whole, another avenue then.
    Mr. Volokh. That is absolutely right. There certainly is no 
software you can write that says, oh, this is obvious parody 
and therefore it should not be taken down or labeled.
    Senator Fischer. Thank you, sir. Thank you, Mr. Chairman.
    Senator Schmitt. Thank you, Senator Cantwell.
    Senator Cantwell. Thank you, Mr. Chairman.
    And thank you Professor Volokh for both the, you know, 
statement you made about Brendan Carr's coercive tactics and 
that that would not be appropriate, and for your 
recommendations on transparency, and rules that I think would 
be a concept of just making sure that things were clear.
    And to my colleague's comment, Senator Klobuchar. 
Definitely, one of the reasons I appreciate many things she 
said, but one of the reasons I support the Blackburn 
Legislation and joined her as a co-sponsor on the COPIED Act is 
because it gives the content holders some rights, and it shows 
who the content holders are, and even in the case of 
compensation, which is an important issue to keeping 
competition and perfect information.
    I will just note that during this debate, this Committee 
and this Body passed a public health emergency language--
related to deceptive practice language. It was unlawful to 
engage in deceptive practices related to the treatment, cure, 
prevention, mitigation, or diagnosis related to COVID.
    Why did we do that? Why did we give that extra power? 
Because there were a lot of crazy things online, like take 
bleach, or what have you, and we wanted to make sure that we 
were being--protecting consumers against deceptive practices, 
as it related to that. That was passed with a very, very big 
bipartisan support by this this--by the Senate, and became law.
    OK. So now to this, Mr. Kimmelman, this larger issue. Even 
my colleague from the House who was Chairman of the China 
Committee, I see does not like the TikTok decision because he 
does not think it goes far enough, and banning you know the 
actual algorithm. We have this attempt by Carr to kind of 
realign the deck chairs at this moment that we have competition 
shrinking. And so that is why it is so concerning to me.
    And the unevenness. We had a hearing here, a Facebook 
whistleblower who literally said the company knew that it was 
putting--elevating hate speech as a way to increase the revenue 
for advertisers. And you know, I feel like that is--you know, 
if a newspaper or a broadcaster puts false information in the 
paper, the community will respond and that person will no 
longer be able to continue their business. But online, you do 
not even know that that is happening.
    And so making sure that we do not have, you know, these 
challenges, what do we need to do to really get people to 
understand that right now you could in a very--I mean, in a 
very vertical way have such an alignment that that influence 
that we are talking about now, of not being coercive, is 
actually done in major ways? Even as my Republican colleague in 
the House is saying he is concerned about this as it relates to 
what TikTok might be doing.
    Mr. Kimmelman. Well, um, Senator Cantwell, I think it is a 
critical issue because as the technology has changed, the 
entire media landscape has changed. So I think we have to 
update our understanding of: Where is the excess power being 
used, how is it being used? These examples you have heard today 
all relate to a gatekeeper in the media landscape that is a 
tech company. We have not always thought of them as being part 
of the same ecosystem, and I think we need to do that.
    Because if you have such enormous power over the major ways 
in which the public gets news, information, can keep up about 
whether it is their community, or matters of public health, or 
national affairs, we have got to make sure that they are 
playing by some reasonable rules, or that there is full 
competition in the marketplace to give people the checks and 
balances in the media. And that is all----
    Senator Cantwell. You do not think Professor Volokh's 
statement about transparency is a bad idea? It is a good idea.
    Mr. Kimmelman. No, it is a great idea. I think transparency 
is one element of this, but it is not enough to prevent the 
kinds of concerns about coercion and suppression if too few 
people have the megaphone, have the ability to turn on the 
microphone for the voices that need to be part of our public 
debate.
    Senator Cantwell. And are you worried about too much 
content being behind paywalls? Because I am. I am worried that 
the more of this vertical integration, and that is why, again, 
I was so concerned about Chairman Carr's comments, in addition 
to the free speech, that if you start using this power as the 
FCC Chairman, and you just allow for all of this vertical 
integration, and the next thing you know, it is kind of like on 
the sports issue you put so much of it behind a paywall, you 
know, how is the consumer just kind of constantly being short-
changed by this whole change in the landscape?
    Mr. Kimmelman. It is a huge problem, and that is why we 
need to make sure there is adequate ways for the companies that 
really invest in news and information, and gathering the 
information that the public wants, engaging people in public 
debate, can finance that and present it, so it is not all 
dumbed down, and kind of diluted in an Internet where there is 
just such massive information flow that you cannot tell fact 
from fiction.
    Senator Cantwell. And you are talking about localism now, 
and that we make sure that we----
    Mr. Kimmelman. Absolutely. It is localism, and it is 
preventing the few companies that seem to have amassed quite a 
bit of power already from getting any larger and acting as 
gatekeepers to our public debate.
    Senator Cantwell. Thank you. Thank you, Mr. Chairman.

               STATEMENT OF HON. BERNIE MORENO, 
                     U.S. SENATOR FROM OHIO

    Senator Moreno. Thank you to all the witnesses for being 
here. If there is no objection, I would like to put into the 
record a letter sent from this committee back in 2018 to the 
Chairman of the FCC requesting that Sinclair Broadcasting 
licenses be reviewed because in the minds of the 12 Democrats, 
including two on this committee, felt that Sinclair was 
perpetuating misinformation.
    We will put that into the record.
    [The information referred to follows:]

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]    

    Senator Moreno. Which I find given the conversations around 
Commissioner Carr, I find that decently ironic.
    Mr. Volokh, I am just----
    Senator Cantwell. Can I just make a----
    Senator Moreno. We can do it then. You had your time. So 
Mr. Volokh, you mentioned that you came to the U.S. 50 years 
ago. We, to this day, congratulations. I came to America a 
little bit more than 50 years ago, which I hate to actually say 
in public testimony, because it makes me feel old. How many TV 
stations you--you are probably like me, had to learn English 
watching TV--how many TV stations and news information sources 
were there by then?
    Mr. Volokh. I do think that----
    Senator Moreno. The button.
    Mr. Volokh. I am sorry.
    Senator Moreno. You have to hit the button so we can hear 
you.
    Mr. Volokh. The button. Sorry. When we came to LA, I think 
there were maybe six or seven VHF. And then if I twiddled the 
antenna around, you get like four or five UHF.
    Senator Moreno. Did you listen to a lot of podcasts?
    Mr. Volokh. I believe that I was not allowed to listen to 
podcasts in 1975, if that----
    Senator Moreno. Well, there was not--it did not exist. It 
did not exist.
    Mr. Volokh. Exactly.
    Senator Moreno. Did you go online and get sources from 
online sources?
    Mr. Volokh. No.
    Senator Moreno. Did you go on X, or Facebook, or Twitter? 
Did you open TikTok?
    Mr. Volokh. I did not.
    Senator Moreno. Did you go on Facebook, Instagram? None of 
that existed? Because I just find it----
    Mr. Volokh. None of that, no.
    Senator Moreno.--I just find it interesting that my 
colleagues are talking about how broadcast TV and monopolism, 
and Mr. Kimmelman, you talked about that which I thought was 
just fascinating that there is all of a sudden, this lack of 
resources to find information when there has never been more 
ways to get information than there is today.
    But Mr. Kimmelman, I have a question for you. You are over 
at the Harvard School; is that correct?
    Mr. Kimmelman. At the Kennedy School, yes, sir.
    Senator Moreno. The Kennedy School? So you would agree with 
all of us, I think, that free speech is important. You would 
agree with George Washington's comment that if freedom of 
speech is taken away, then dumb and silent, we may be led like 
sheep to the slaughter. You would agree with that, right?
    Mr. Kimmelman. Certainly.
    Senator Moreno. What are you doing about Harvard's F rating 
for free speech?
    Mr. Kimmelman. I am a fellow at the Kennedy School, I have 
a very----
    Senator Moreno. No. I mean, have you spoken to your 
colleagues? Have you made a protest? Have you rallied the 
students to say: How do we get rid of this F rating? I mean, I 
cannot imagine Harvard students would find it objectionable to 
have an F in anything. What are you doing about fixing Harvard?
    Mr. Kimmelman. There is a lot of discussion I know around 
me about trying to make sure there is an open environment for 
learning and----
    Senator Moreno. But they have an F rating, just to be 
clear. They have an F rating. Harvard University has an F 
rating in free speech. And you are here giving us lectures on 
free speech. Does not exactly--ring very hollow.
    Mr. Berenson, a quick question for you. We need to put on 
the record. What was the outrageous things that you said in 
2021 that got you thrown off Twitter? I mean, were you planning 
to overthrow the United States government? Were you creating a 
militia? Like, give me an example. Give me a flavor of the 
outrageous things that you must have said?
    Mr. Berenson. The tweet that got me banned from Twitter on 
August 28, 2021, begin, ``It does not stop infection or 
transmission''.
    Senator Moreno. What?
    Mr. Berenson. Yes.
    Senator Moreno. Are you saying that a mask--a cloth mask 
does not stop the spread of COVID, how dare you say those kinds 
of outrageous comments?
    Mr. Berenson. I said that the mRNA vaccine did not stop 
infection or transmission.
    Senator Moreno. And did it?
    Mr. Berenson. I mean, I think I might be the only person in 
this room who was not vaccinated with the mRNA vaccine. And we 
all got COVID.
    Senator Moreno. Did the vaccine stop the spread?
    Mr. Berenson. No. No, of course not.
    Senator Moreno. So you were allowed to be wrong, but you 
were right. Does that make it--now, what accountability has 
been in place for that? Like who has been held accountable for 
this?
    Mr. Berenson. Well, Twitter actually admitted that they 
should not have done that.
    Senator Moreno. Yes, you know they admitted it, but what 
accountability? Because that cost you money, that cost you 
direct----
    Mr. Berenson. Oh, yes.
    Senator Moreno.--money in your pocketbook. What 
accountability has been put in place?
    Mr. Berenson. There has been no--I mean, more important 
than accountability, I did not get to tell people what I 
thought and there were--I mean, I was getting hundreds of 
millions of views a month. People wanted to hear what I 
thought, and the Biden administration did not like it and they 
forced Twitter to ban me. And I will also say it is a way----
    Senator Moreno. So you are saying--you are saying the U.S. 
Government, elected officials, who swore an oath to the 
Constitution told private media companies to terminate your 
account which cost you your money? I assume you are not 
naturally wealthy from five generations of wealth, and that you 
actually have to work for a living, and that ability to earn an 
income was taken away from you because you dared to have an 
opinion on a vaccine?
    Mr. Berenson. I regard it as more important that I was not 
able to say what I thought. The money matters less to me. And I 
also have to say this, Pfizer made $100 billion selling that 
vaccine, and Pfizer officials cooperated or collaborated with 
the Biden administration. It is a scandal.
    Senator Moreno. Yes.
    Mr. Berenson. Let me just say one thing. If I had been 
reporting on plane crashes and Boeing had colluded with the 
Biden administration or the Trump administration, it would be a 
national scandal that a Boeing official had leaned on a social 
media company.
    Senator Moreno. Yes.
    Mr. Berenson. But Pfizer somehow got away with this.
    Senator Moreno. Yes. And in the--her opening statement, the 
Ranking Member talked extensively about protecting free speech, 
but then stated she was not referring to hate speech. I think 
what maybe my colleagues mean to say is speech that they hate.
    Mr. Berenson. That is right.
    Senator Moreno. Because it is--hate speech is in the eye of 
the beholder. Would you agree, Mr. Davis?
    Mr. Davis. I completely agree. Hate speech, misinformation, 
disinformation, they are just fancy words that people use to 
shut down speech they do not like.
    Senator Moreno. Right. So if I say that there is only--such 
thing as a man and woman, that maybe when I got to the U.S. 50-
plus years ago, somebody would have said, why did you say that, 
like obviously there is only men and women. I come from a 
culture where our entire language is male or female, but that 
could be considered hate speech, right, if I say that?
    Mr. Davis. It was for a long time, if you said that on 
Twitter for several years you ran the risk of being censored, 
shadow-banned, or permanently suspended.
    Senator Moreno. Well, obviously we will talk more about 
this topic. I do find it interesting that my colleagues who 
were totally and completely complicit during the Biden era, 
that were absolutely applauding people being thrown off social 
media, that were saying that any commentary about a Hunter 
Biden laptop story being misinformation was considered an 
insurrectionist.
    That now all of a sudden clutch their pearls because a 
moronic, second-rate comedian who makes $16 million a year got 
fired from his job for having atrocious ratings, is somehow now 
an attack on free speech. I do not know that they have the 
moral high ground here, but thank you for your testimony.
    And I recognize the Senator from Nevada.

                STATEMENT OF HON. JACKY ROSEN, 
                    U.S. SENATOR FROM NEVADA

    Senator Rosen. Thank you. Thank you for being here today 
and speaking your mind. It is about the First Amendment. 
Appreciate that because the freedom to express yourself and 
speak your mind is the cornerstone of America. It is one of the 
main ways we distinguish ourselves from other nations. In the 
United States, you are free to criticize whomever you want, 
including government leaders, without government censorship.
    And so it is wholly appropriate and indeed necessary for 
this committee to hold oversight hearings that focus on 
protecting this critical right from being eroded by anyone. But 
that is not the focus of today's hearing. Rather than providing 
us with a forum that will evaluate truly harmful government 
censorship.
    This has become increasingly commonplace under the Trump 
administration, are undertaking an effort to settle old 
political scores against an administration that is no longer in 
power. There are issues that we have to deal with, and we do 
want to support and we must support free speech, but this 
hearing is not the place.
    Two weeks ago, I sent a letter to Chairman Cruz calling for 
the FCC Chairman to testify before this Committee after he 
threatened to revoke broadcast licenses over Jimmy Kimmel's 
comments criticizing President Trump. I was particularly 
concerned as I know the Chair was from his statements calling 
the threat mafia-like. Chairman Cruz called the threats mafia-
like, with his clear attempt to suppress speech, a comedian.
    However, I am disappointed that that is not what is the 
focus of today's hearing. Chairman Carr's later backtracking, 
claiming there is some sort of local community exception to the 
First Amendment. There is no exception. You have free speech or 
you do not. We know those limits. There is precedent for that. 
His comments, Chairman Carr's, were reprehensible and this 
demands a full accountability, and we demand full 
accountability.
    Indeed, his weak excuses have been repeatedly contradicted 
by the President's own statements. President Trump has said 
outright that the reason the FCC should revoke broadcast 
licenses is because of negative coverage of his administration. 
I want there to be journalist that looks at things. This is the 
clearest possible violation of the First Amendment.
    The President of the United States directing an agency to 
revoke a license of networks that run a critical story of him. 
There never would have been press, or print, or TV, or radio. 
You could go back 250 years if all presidents did this.
    This is a government--this is government censorship by our 
President. Plain and simple. It is what they do in Russia. It 
is what they do in North Korea. It is what they do in China. It 
is not what we do in a democracy that has a First Amendment.
    Those attacks on free speech. They harm not only our 
democracy but our economy. Last month it was Brendan Carr's 
interference in the private business decisions of large media 
companies. But tomorrow could be tech, energy, tourism, any 
other industry could be impacted.
    In Las Vegas, we are seeing fewer international tourists 
because people are afraid to come to the U.S. under this 
administration. People planning to travel to the U.S. see this 
administration detaining people for posting something online 
that is critical of the President in another country where they 
live, and they cancel their trips to America out of fear of 
U.S. Government retaliation. And the consequences for our 
economy are substantial.
    So Mr. Kimmelman, can you discuss the direct impacts of 
infringement on speech rights, and can you tell us what you see 
as the biggest threat to the First Amendment, writ large, 
please?
    Mr. Kimmelman. Sure. Well, the threats, coercion, chill 
speech. Either they suppress directly or create an environment 
in which everyone is afraid to speak his or her mind, to engage 
in debate, to have the kind of open discussion that our 
democracy requires. So it is extremely dangerous. Obviously, as 
you point out, when the government does it directly, it is 
horrible. It is a First Amendment violation. It needs to be 
stopped.
    But it also can happen when tech platforms become too 
powerful, when they do not face competition, when they play a 
gatekeeper role. This could be the same if there is too much 
roll up of media, and it is the most popular media. Senator 
Moreno made a good point. There is a lot of--there is so much 
more out there than before. But it is not just availability. It 
is what do people rely upon? What is most popular? What do they 
need to get news and information?
    And so anywhere there is a chokehold, I think there is an 
appropriate question of: Is it too much concentration? Is it 
too much power? Does it work for our democracy? And that is 
where Congress has a role to set guardrails.
    Senator Rosen. Thank you. I see my time is up. Appreciate 
this hearing and wish that we would be having Chairman Carr 
here to discuss some of free speech and the open platforms. And 
I look forward to Chairman Cruz working with us to get that on 
the docket. Thank you.
    Senator Schmitt. Thank you, Senator. I am told that we will 
do that. We need to open the Government up first, right? That 
is the first priority.
    I will also note that I asked the Chairwoman to have Lina 
Khan come before this Committee. Never came in my two years. I 
asked for Pete Buttigieg to appear, the Secretary of 
Transportation, never appeared in my two years, but I know the 
Chairman is committed to having the FCC and the FTC here.
    Senator Blackburn.

              STATEMENT OF HON. MARSHA BLACKBURN, 
                  U.S. SENATOR FROM TENNESSEE

    Senator Blackburn. Thank you, Mr. Chairman. That is exactly 
right. we are looking forward to being able to return to 
regular order and to do oversight.
    Just one item I want to mention. There was a comment: 
Tourists are not coming because they are fearful of words. 
Tourists are not coming because they are fearful of crime. And 
there are so many stories that bear this out. When you look at 
New York City, when you look at Chicago, when you look at the 
effect that violent crime is having in some of these cities, I 
am very grateful that President Trump has made it a priority to 
address this.
    We are seeing fantastic results in Memphis from the 
increased presence that is there from the Memphis Safe Task 
Force, which is 13 Federal agencies. The Tennessee Bureau of 
Investigation, the Tennessee Highway Patrol, the National Guard 
will be going in there this week to assist the Memphis PD. They 
have arrested nearly a thousand gang members, and they have 
already started the process with indictments, and moving these 
criminals into court.
    And indeed, we are very grateful for that, and we know the 
crime level needs to come down in these big cities so people do 
want to go to these cities.
    Mr. Davis, always good to see you. Grateful that you are 
here, and for the good work that you all do. I am pleased that 
Ms. Hemingway is here today also.
    I want to talk with you a little bit because I know The 
Federalist and your team at The Federalist was constantly on 
the receiving end of some of these attacks and actions from the 
Biden administration. And I would like to hear you talk about 
why you all were on the receiving end, why you felt like you 
were on that, and why you were accused of misinformation, and 
why their goal was to always shut you up?
    And we know that the left made great sport out of shutting 
up conservatives, and attacking conservatives. And as we 
learned this week, surveilling conservatives. And of course, 
seven of my Senate colleagues and I found out that the FBI was 
surveilling us, and pulling our phone records. And I think it 
would be helpful if our colleagues across the dais wanted to 
join us in calling the FBI--the Biden-led FBI out about those 
actions.
    But lay out for me what you all experienced and why you 
felt like it was such a repeated attack on you and The 
Federalist?
    Mr. Davis. Well, thank you, Senator. It is an honor to be 
here in front of you. And wonderful to see you as always. You 
pose a great question. Why were we targeted? I am reminded of 
the quote, I think it was the baseball player Reggie Jackson: 
They do not boo nobodies. Well, they do not censor nobodies 
either. In fact, that it is the most effective voices which 
tend to be targeted for censorship.
    And at The Federalist we are extremely effective at tearing 
down false narratives and reporting the facts. We have a team 
of absolutely fearless, courageous journalists who get up every 
day to tell the truth and report the facts, especially when 
they might be facts the government does not want people to 
hear. And so they targeted us because we were effective, 
because we were exposing the lies about the Russia collusion 
hoax, about the Kavanaugh hoax, about COVID-19 lies that it 
came out of a wet market in China.
    We were exposing ridiculous new election laws that ignored 
existing laws in the Constitution in 2020. We exposed the whole 
Hunter Biden laptop thing, which was 100 percent real. It was 
not a hoax. Somebody remarked earlier that: Oh well, you have 
the market to take care of if a newspaper or a network says 
something that is not true, why people will not follow them. 
Well, we know that is not true because MSNBC and CNN, they are 
all still around. They lied repeatedly. They were not targeted 
for censorship.
    And I have to say, it is nice to be here to hear a 
bipartisan support for free speech. Man, I wish a lot of you 
all were helping us as the Biden administration was censoring 
us. We have been in Federal court for two years trying to 
vindicate our free speech rights. And I have got to tell you, 
it is pretty aggravating being an American citizen whose family 
has been here for hundreds and hundreds of years, to see 
illegal immigrants get faster action in Federal district courts 
than we have gotten.
    We are still awaiting vindication and relief. And we were 
not targeted because what we were saying was false. We were 
targeted because what we were saying was true.
    Senator Blackburn. And how much, talk to me about the 
expense of having to be tied up with trying to get your day in 
court for that period of time?
    Mr. Davis. You know, it is extensive. Thankfully we have 
lawyers who are representing us out of the goodness of their 
own hearts. But if you look at the effect of censorship over 
years, Alex made the great point that you cannot compensate 
someone for the crime of having shut them up, by unjustified 
means for years. That speech that he should have been able to 
give for years, he can never give. That that opportunity is 
gone.
    But there is also a real cost in terms of money. I cannot 
even begin to think about how many millions or tens of millions 
of dollars we lost out on because our advertisers were 
targeted, because our readers were targeted, because Facebook, 
and Google, and Twitter, and YouTube were told to throttle us. 
It has to be in the millions or tens of millions of dollars. 
Quite frankly, we are owed restitution.
    Senator Blackburn. Thank you. Thank you, Mr. Chairman.
    Senator Schmitt. Thank you. Well, I am sure you will 
support my legislation which would give a private right of 
action to a citizen to sue an individual government bureaucrat 
for suppression of speech. I think that turns the tables on the 
incentive structure that currently exists.
    Senator Markey.

               STATEMENT OF HON. EDWARD MARKEY, 
                U.S. SENATOR FROM MASSACHUSETTS

    Senator Markey. Thank you, Mr. Chairman.
    We have heard a lot today about the Biden administration 
supposedly censoring of conservatives by talking to social 
media companies about misinformation. Republicans have wasted 
an enormous amount of time and resources over the past few 
years attempting to prove this theory correct, only for it to 
be repeatedly proven false.
    The Supreme Court shot down their big lawsuit against the 
Biden administration in a 6 to 3 vote. Their big House 
Judiciary Committee investigation came up empty. And in the 
Chairman's Report last week, the supposedly incriminating e-
mails from Biden administration officials pressuring the big 
tech platforms to censor conservatives, including--included 
explicit disclaimers that the officials were not threatening 
any action against any platform. Strike one, strike two, strike 
three, you are out, Republican theory of censorship.
    Since my Republican colleagues seem confused about what 
actual government censorship looks like, I thought I could show 
a few of them to you. It is not just the mafia boss threats 
from Brendan Carr at the FCC to Disney and ABC, on six 
different occasions Donald Trump took office and he now has 
posted on Truth Social explicitly calling for the Federal 
Communications Commission to revoke broadcast station licenses 
owned by major networks over their editorial decisions.
    On February 6, Trump said CBS should, quote, ``Lose its 
licenses'' over its interview of Vice President Kamala Harris 
in the fall of 2024. Just over TWO months later, on April 13, 
Trump again said ``CBS should lose its license for its Harris 
interview''. On July 26, Trump wrote: ``Networks are not 
allowed to be political pawns for the Democratic Party''.
    It has become so outrageous that in my opinion, their 
licenses could and should be revoked. On August 24, that was a 
big day for unconstitutional threats. Twice in under an hour, 
Trump said that ``ABC and NBC should lose their licenses''. And 
then just last Sunday, Trump said the FCC should quote, ``Look 
into the license of NBC''.
    Mr. Kimmelman, do you agree that the explicit threats from 
the President of the United States against broadcasters are far 
more dangerous than e-mails from the Biden administration 
officials identifying online misinformation?
    Mr. Kimmelman. Yes.
    Senator Markey. Mr. Kimmelman, how many times did President 
Biden threaten to revoke a broadcast license in our country?
    Mr. Kimmelman. None to my knowledge.
    Senator Markey. Mr. Kimmelman, how many times did President 
Biden publicly direct his FCC Chairman to look into a 
broadcaster's license?
    Mr. Kimmelman. None to my knowledge.
    Senator Markey. Again, zero. This hearing is a farce. We 
are not focusing upon the imminent threat to the First 
Amendment. The beating heart of democracy, freedom of speech, 
freedom of press. That is what this hearing should be about. 
What is going on at the FCC right now.
    We are relitigating an issue that the Supreme Court has 
already decided, that in fact independent analysts have 
debunked even as President Trump and Federal Communications 
Chairman Brendan Carr and other Trump officials wage a war on 
free speech that this country has not seen since the McCarthy 
Era in the 1950s. Like during that Red Scare, if you are a 
voice of dissent in this country, you have a target on your 
back. And they let you know you have a target on your back if 
you speak up.
    Law firms, universities, protesters, news media, all have 
faced this administration's wrath for their political speech. 
These threats are real. They are scary and they undermine our 
democracy. The President is threatening the free speech of the 
broadcasters in our country every time they dare to run some 
news story that questions their judgment as an administration.
    Yet, we are wasting time here trying to distract the 
American people with old e-mails from the Biden administration, 
while Chairman Carr turns the FCC into the Federal Censorship 
Commission, threatening free speech, censoring free speech in 
our country, allowing Donald Trump to continue with his direct 
attacks on the First Amendment in our country.
    This is an urgent crisis for our country. Our democracy is 
at risk when the First Amendment is being challenged so 
fundamentally by the President out of the White House and 
instructing his Chairman of the Federal Communications 
Commission to revoke the licenses of anyone who dares run any 
program that runs contrary to his views. That is what we should 
be focusing upon right now. That is the threat to our 
democracy.
    Thank you, Mr. Chairman.
    Senator Schmitt. Thank you, Senator. And a mixed 
sportsman----
    Senator Moreno. Mr. Chairman? Mr. Chairman, just a quick 
question to my colleague, just 5 seconds. Did you sign on to 
that letter asking the FCC to revoke the license of Sinclair 
Broadcasting in 2018?
    Senator Markey. I will have to go in to review that, but 
from my perspective, what Trump is doing right now at a 
Presidential level, ordering the FCC to act is absolutely an 
imminent threat to our democracy.
    Senator Schmitt. OK. And I also mixing sports metaphors on 
your strikes. I am going to throw the red flag because the 
Federal District Court, I know something about this, said that 
the Biden administration had engaged in the worst example of 
violation of the First Amendment in American history. That 
decision was upheld by the Fifth Circuit. The Supreme Court did 
not rule against it. It sent it down. It did not rule on the 
merits. It sent it down for a standing issue.
    So Senator Peters.

                STATEMENT OF HON. GARY PETERS, 
                   U.S. SENATOR FROM MICHIGAN

    Senator Peters. Thank you, Mr. Chairman. I had first just 
like to start by making a very clear statement. Government 
censorship is wrong. Full stop. Never should be should be 
tolerated. That should be no matter what side of the aisle that 
you are on. I think we can agree that the government takes when 
it--when government takes adverse action against speech that it 
dislikes, that is bad for all Americans, and it is counter to 
the fundamental values that this country stands for.
    As Ranking Member of Homeland Security and Governmental 
Affairs Committee, I have reviewed thousands of pages of 
documents, including testimony from the cybersecurity and 
infrastructure agency employees. And I will say that I simply 
do not agree that CISA, the agency, has worked in a coordinated 
effort to censor American speech. And the Supreme Court has 
basically agreed with that finding.
    However, if there is evidence, if there is evidence of 
wrongdoing on the part of anyone in previous administrations, I 
want to address it and I will work with folks on this panel to 
do that. Protecting free speech should not be--should not be a 
partisan issue. And that is why I am disappointed that instead 
of having the FCC here today to discuss what are urgent and I 
believe a flagrant violation of America's First Amendment 
rights, as my colleague just mentioned before me, instead we 
are rehashing debunked claims regarding activities at CISA from 
2018 to 2022.
    Since it was created in 2018, CISA has protected our Nation 
against cyber criminals and foreign adversaries who are 
constantly, constantly seeking to breach critical networks and 
steal America's most sensitive personal information. And 
unfortunately, today we are hearing claims that have been 
debunked about the Agency's mission and its vital work.
    The Supreme Court decision in Murthy v. Missouri found with 
regard to CISA, quote, ``The evidence does not support the 
conclusions that the relevant plaintiff made that CISA had 
violated the First Amendment Rights.'' So it is a Supreme Court 
decision.
    None of the documents I reviewed included instructions for 
the social media platforms to respond to CISA's questions on 
flagged content, nor did they attempt to cover up their 
interaction in some way with these companies.
    So it is concerning to me that the Committee would choose 
to focus on a backward-looking claim at a time when today, 
currently, we are seeing unprecedented efforts to wield 
government power as a tool to suppress free speech and stifle 
legitimate criticism, and legitimate political discourse.
    In recent months, the Trump administration has revoked 
media access, revoked media access, got to say it again, over 
news coverage that did not flatter the President. Oh, my gosh, 
horrible. You did not flatter the President. You cannot have 
media access. That is a high crime and misdemeanor, apparently. 
He also sued media outlets who publish content that the 
President does not agree with. And he has launched baseless 
investigations into the President's perceived political 
enemies.
    In one instance, the President's FCC Chair, Brendan Carr, 
threatened to revoke the broadcast licenses of ABA [sic] 
affiliates over comments made by a comedian. Oh, my, gosh, 
horrible, comedian comments. Revoke that license. President did 
not like the comedy.
    Let us be clear, these acts are unprecedented. 
Unprecedented in American history, and they rightfully raise 
alarms, I think, for every American. Thousands of Michiganders 
have reached out to my office saying that we must hold the 
Trump administration accountable to ensure that these abuses of 
power are not left unchecked.
    And I certainly hope that the Chairman of this Committee, 
and members of the Committee will devote their efforts to 
examining these abuses that I mentioned, regardless of who 
commits them because we must all stand up for First Amendment 
rights in the face of unprecedented overreach. And it is right 
to call out wherever we see it, no matter who is saying it, no 
matter what administration, but let us not ignore what we are 
seeing in front of us right now, constantly, in the media.
    So Mr. Kimmelman, a quick question. After threatening 
regulatory action against ABC affiliates if it did not suspend 
Jimmy Kimmel, FCC Chair Brendan Carr said, quote, ``If you are 
going to have a license from the FCC, we expect you to broadly 
serve the public interest''; end of quote.
    So my question for you, sir, is there precedent for the FCC 
using the public interest convenience and necessity standard in 
the Communications Act to stifle First Amendment protected 
speech? And how has the FCC historically interpreted the public 
interest? How is this different?
    Mr. Kimmelman. Not to my knowledge, Senator. The FCC has 
used--it is a public interest standard--the FCC has used it 
very carefully. There is specific direction in the 
Communications Act beyond the Constitution itself of Congress 
reminding the FCC not to stifle speech, not to impede First 
Amendment rights. And the FCC has been very careful in that 
regard.
    Senator Peters. So the comments made by the current FCC 
Chair is simply unprecedented, in all of your knowledge of past 
actions?
    Mr. Kimmelman. In my experience, Senator, I have been doing 
this for more than 45 years. I have never seen anything like 
that.
    Senator Peters. That is perhaps why it was so shocking to 
Americans all over this country, but apparently not to some 
individuals serving in the U.S. Senate.
    Thank you. Thank you, Mr. Chairman.
    Senator Schmitt. Thank you, Senator. Senator Lujan.

               STATEMENT OF HON. BEN RAY LUJAN, 
                  U.S. SENATOR FROM NEW MEXICO

    Senator Lujan. Thank you, Mr. Chairman. Mr. Chairman, 
before I begin, one of my colleagues raised a letter that was 
sent to the FCC back in 2018, that was signed by Democrats. I 
do not know how many of you know who the Chair of the FCC was 
in 2018. Do any of you know? Does the name Ajit Pai sound 
familiar?
    You know who was president in 2018? Donald Trump. I am 
sorry if I stumped you all. It was Chairman Pai that denied 
this thing. And Chairman Pai in his order, he said something 
along the lines of: What was submitted to the FCC lacked 
candor.
    It is funny to me how there are so many legal ways to call 
a lie a lie. When the FCC says a submission lacks candor, it 
means that it intentionally provided false or misleading 
information omitting crucial facts. Just so that the record is 
straight.
    Mr. Volokh, just a few weeks ago, the Federal 
Communications Commission Chairman, Brendan Carr, made several 
statements. You heard a lot of them today with regulatory 
action over remarks made by Jimmy Kimmel if they, quote, ``Did 
not take action''. In his own words, Chairman Carr said, quote, 
``We can do this the easy way or the hard way.''
    Now, to be clear, ABC can suspend Jimmy Kimmel's show for 
whatever reason they want. However, the fact pattern that led 
ABC to suspend Jimmy Kimmel's show involved a government 
official, in this case FCC Chair Carr, making direct threats.
    As you have written, quote, ``But if the Government coerced 
ABC into suspending the show through threats or of retaliation, 
that would have likely violated the First Amendment.''
    Yes, or no, if ABC acted to remove Jimmy Kimmel because of 
FCC Chairman Carr's threats, would Carr's actions violate the 
First Amendment?
    Mr. Volokh. Yes, I think so.
    Senator Lujan. Unfortunately, the events from a few weeks 
ago related to Kimmel's show was not the first time that 
Chairman Carr has weaponized the FCC against broadcasters since 
he took office.
    Mr. Kimmelman, I would like for you to help get some facts 
on the record. I think you answered these to Chairman Markey, 
but questions sometimes need to be heard twice, and as the 
responses. Did President Biden ever direct Chair Rosenworcel to 
investigate a media company, pull their license, and: Impose 
the maximum fines and punishment, by the way that is a quote 
for from Donald Trump, for their unlawful and illegal behavior 
immediately after threatening to sue that company?
    Mr. Kimmelman. No, Senator.
    Senator Lujan. Did President Biden suggest Chair 
Rosenworcel should revoke broadcaster licenses for giving him, 
quote, ``Bad publicity''?
    Mr. Kimmelman. No, sir.
    Senator Lujan. Did Chairman Carr reinstate complaints 
against NBC, ABC, and CBS for election coverage that were 
dismissed by the prior FCC?
    Mr. Kimmelman. Yes, Senator.
    Senator Lujan. Did Chairman Carr launch investigations into 
local NPR, PBS stations alleging that they could be violating 
Federal Law by airing commercials?
    Mr. Kimmelman. Yes, Senator.
    Senator Lujan. Has Chairman Carr openly threatened to 
remove Comcast broadcast license over a news coverage?
    Mr. Kimmelman. Yes, Senator.
    Senator Lujan. Now look, what is disappointing is that is 
just a sample of what is recently happened. And I appreciate 
this hearing. I think this was a good hearing. There are a few 
of us that actually authored legislation to say FCC, keep your 
hands off of these media companies. Protect the First 
Amendment. Follow the law. I hope that is something that you 
all will take a look at and see if maybe there is 
bipartisanship. And if anyone is worried about doing it under 
this president, let us say the next president, let us just say 
let us take this off the table. So I certainly hope that is 
something that we can all do together.
    Now, Mr. Kimmelman, President Trump has developed a habit 
of suing media companies if they report or publish content he 
does not like. He sued CNN, ABC, CBS, Washington Post, Wall 
Street Journal. I mean, it goes on and on. Trump even sued the 
Pulitzer Prize winner to the New York Times and Washington Post 
for their reporting about Russian interference in the 2016 
election.
    Now, some of the media companies such as ABC and CBS chose 
to settle, others are still fighting. Even if a lawsuit is 
baseless, what effect does it have on the opposing part party, 
Mr. Kimmelman?
    Mr. Kimmelman. Senator, it has an enormous chilling effect. 
Even as you have heard from these, my colleagues on this panel 
here in a different context, it is overwhelming to take on the 
government even if you think you can vindicate your rights. It 
is a daunting task, and it tends to pull people away from 
presenting the views, or actually trying to vindicate their 
rights because it is such an overwhelmingly costly endeavor.
    Senator Lujan. Look, I think it is fact that Meta paid $22 
million to President Trump to settle a lawsuit. Did Paramount 
pay, yes, $16 million to President Trump as well? after 
Skydance settled, there was a merger approved within days as 
well.
    As a matter of fact, my team looked into the last time that 
a president sued one of these media companies. They had to go 
back to Teddy Roosevelt to find it. And do you know how much 
the settlement was for? Six cents.
    Anyhow, there is a little trivia for you all as well. Look, 
as my time concludes. Mr. Davis, I do not know if you have ever 
been asked this. I cannot find anywhere on the record where you 
have answered it. Who won the 2024 election in the United 
States of America?
    Mr. Davis. Who won the 2024 election?
    Senator Lujan. Yes, for President?
    Mr. Davis. Joe Biden was elected President.
    Senator Lujan. In 2024?
    Mr. Davis. Oh. Excuse me. sorry, had 2020----
    Senator Lujan. Now, misinformation right there. So let us 
set the record straight. Who won the 2024 election?
    Mr. Davis. I was in government censorship mode. Donald 
Trump won the 2024 election.
    Senator Lujan. Who won the 2020 election?
    Mr. Davis. Joe Biden was elected President in 2020.
    Senator Lujan. I appreciate that very much.
    Mr. Chairman, I yield back.
    Senator Schmitt. Thank you. Well, since we are doing some 
Presidential history, Mr. Davis, could you name the last 
president that was a prosecutor attempted to throw in jail for 
the rest of his life and impoverish his family, has that ever 
happened?
    Mr. Davis. Yes, I recall Donald Trump being threatened, 
right----
    Senator Schmitt. The only one, not even Teddy Roosevelt. 
Since we are going back in time. I do want to ask you, you Mr. 
Kimmelman, because just as a follow up for, and I am going to 
get to you just very quickly. The question was a president 
suing a news organization and you said that the government 
taking that on would have a chilling effect. You are not 
arguing that an individual citizen as President Trump suing a 
media company for lies is a threat to the First Amendment, 
right?
    Mr. Kimmelman. No. No, I am not.
    Senator Schmitt. OK. Thank you.
    Senator Blunt Rochester.

            STATEMENT OF HON. LISA BLUNT ROCHESTER, 
                   U.S. SENATOR FROM DELAWARE

    Senator Blunt Rochester. Thank you Mr. Chairman. To my 
colleagues, yesterday there was a split screen on the news. 
Coverage of committee hearings and a shutdown clock. It was a 
tale of two realities. Republicans continue to call for 
hearings like it is business as usual, while Americans are 
literally living in the midst of a shutdown that jeopardizes 
their health, that jeopardizes their jobs, and the services 
that Americans rely on.
    So the issues before us are vitally important, but our 
number one priority in this moment should be reopening the 
government and restoring people's healthcare.
    So today, I want to use my time to remind all of us what is 
at stake. We are in a pivotal moment. Energy costs are up. Food 
prices are up. The rent has gone up for many. And millions of 
Americans in red states and blue states alike are on the brink 
of their health care costs doubling or losing it altogether. 
From small businesses, to farmers, to ranchers, to moms and 
dads, at this very moment, Americans across our Nation are 
making some very difficult decisions about how to make ends 
meet.
    We can fix this. But it requires negotiations. It requires 
us all to do our jobs, and to find a path forward together. We 
can reopen the Government. We can restore health care for the 
millions of Americans who are counting on us. But it requires 
urgency, and it requires trust, and it requires willingness to 
come to the table now.
    My Republican colleagues control the White House, the 
House, and the Senate. The ball is in your court. Let us make a 
deal.
    Thank you. And I yield back, Mr. Chairman.
    Senator Schmitt. Thank you, Senator. I want to ask just a 
couple of questions before we close out here, because this is a 
topic of great interest to me.
    Mr. Davis, obviously this agenda that was at work cost you 
a lot, critical resources, for your publication, your family. 
Given organizations like, I mean, there are so many of these 
that I just do not have time to go into them. I mean, the truth 
of the matter is what was uncovered was that, you know, we took 
their deposition.
    The CDC had approved words and phrases that social media 
companies could use in this secret portal that was established 
between the government and these social media companies 
conveyed this, and if people utter this phrase, I mean, this is 
sort of like--this is prior restraint, sort of like this is 
what you will take down ahead of time.
    CISA was very much involved in this. You have an alphabet 
soup of agencies most people have never heard of that were 
weaponized against millions of voices in this country. We talk 
about President Trump a lot but there is just a lot of just 
people who were online who had questions about forced masking 
of kids, or the vaccine mandate all those sorts of things and 
they were throttled or taken down.
    So given what you knew about organizations like--the 
Election Integrity Project, that is another one, in 
collaboration with CISA and received taxpayer funding, how are 
these NGOs still working currently to harm individuals from 
speaking their mind, particularly conservatives?
    Mr. Davis. Yes, it is a great question. The thing about 
these censorship tools, and technologies, and efforts is they 
are a little bit like injecting something into the body's 
bloodstream. They inject it in, it is in there, it is working 
its thing. And just because you pull the needle out does not 
mean the effects are gone. A lot of these organizations are 
still out there using technologies, and tools, that were 
deliberately funded and distributed by the Federal Government 
for the purpose of censoring people like me, people like Alex 
Berenson, people like my colleague Mollie Hemingway.
    I do not know if we will ever actually be free of the 
effects of this censorship industrial complex that the previous 
administration created. I do not know if we will ever be free 
of the horrible effect that it created. The horrible dampening 
and abridgement of our speech that we were forced to endure, 
secretly, for years and the extent of which we still do not 
fully know.
    Senator Schmitt. Mr. Berenson, I want to ask you. What is 
the most--in your kind of review of all this stuff after the 
fact, what is the single--it is hard to probably pick one--what 
is the most shocking thing that sort of you uncovered or found 
out about this whole thing, your experience?
    Mr. Berenson. That the White House would directly target me 
as an individual, you know, and again RFK. I think the White 
House, the Federal Government has tremendous power it is more 
than it should go out there and say what it thinks, and if it 
wants to promote mask, or whatever it wants to promote, 
obviously it has every right to do that, but to target 
individuals or target entire classes of speech I just do not 
understand how anybody thought that was OK.
    And clearly, I will tell you actually what the most 
stunning thing was. The companies did not like it. OK. You had 
private companies saying: Hey, we are worried about the First 
Amendment. You had you had a British politician, the former 
deputy prime minister of Britain saying to the White House: I 
think there is a problem here. And the White House said: Oh. 
No, do not worry about it.
    Senator Schmitt. And then last, then I will get to Senator 
Hickenlooper.
    Mr. Volokh, I want to ask you. The NIST, AI Risk Management 
Framework Guidance advises developers, this is a government 
agency, advises developers to mitigate risks related to quote, 
``Harmful bias'' and content that may not, quote, ``distinguish 
fact from opinion or fiction''. From a First Amendment 
perspective, what is the danger of the government suggesting 
that these AI companies or other platforms should filter out 
quote/unquote ``harm'', or quote/unquote, ``bias''?
    Mr. Volokh. Well, if the government--I am sorry--if the 
government were to mandate that AI companies restrict their 
outputs in particular ways, I think that would violate the 
First Amendment partly because of the rights of the companies, 
but partly because of the rights of users, users as listeners, 
users as people who would want to use the AI to create their 
own speech.
    At the same time, when it comes to government procurement 
decisions, government needs to get AI for its own purposes, it 
has to insist that the AIs provide accurate information. I am 
still----
    Senator Schmitt. You understand the danger of that though, 
right?
    Mr. Volokh. There is definitely a danger, but at the same 
time, again, the government as buyer, the purpose of AI is to 
provide accurate information. Social media, I think the main 
purpose is to provide information that users supply. It is to 
provide, I think, should be a largely unfiltered channel----
    Senator Schmitt. A passthrough platform----
    Mr. Volokh. Right.
    Senator Schmitt.--which is why they are given the Section 
230 protections in the first place, correct?
    Mr. Volokh. Well, I do think that that is the--that that is 
a good model as a passthrough platform. But AI cannot be to be 
effective a passthrough platform. It has to make decisions that 
we hope are decisions in favor of more accurate information. 
Otherwise, the government, as a user of AI, will be constantly 
deceived by it.
    So I think as in its procurement capacity the government 
needs to be able to insist that the AI companies do what it 
takes to provide more accurate information, and to fight indeed 
misinformation in their own output. That is something that is 
required. And indeed, AI companies do not have Section 230 
immunity in that context, that we----
    Senator Schmitt. Correct. And I suppose--I think this is 
going to be a big issue, whether you call it Woke AI, whatever.
    Mr. Volokh. Um-hum.
    Senator Schmitt. The previous administration, one of the 
untold stories to lock in, and I actually agree with Mr. 
Kimmelman on this point, to lock in the incumbents and the 
monopolies in exchange for that was to have algorithms that 
locked in this bias. And that is a very, very dangerous road to 
go down. So I do not think this is the last we are going to--is 
not really the purpose of this hearing, but since we are having 
the discussion, I think it is really kind of an interesting and 
important thing.
    So, Senator Hickenlooper.

             STATEMENT OF HON. JOHN HICKENLOOPER, 
                   U.S. SENATOR FROM COLORADO

    Senator Hickenlooper. Thank you, Mr. Chair, and I agree 
completely that what we should be looking at is the algorithms 
as much as the speech because those algorithms are going to 
control what we get. And in a funny way that is an abrasive and 
intrusive form of speech that has almost nothing to do with 
your freedoms.
    Let me just start just by saying that the First Amendment 
to most of us is a bedrock of our country, it is a bedrock of a 
healthy democracy. It protects people from government 
censorship at every level. It provides free speech, but it is 
not unlimited. And we know that speech encourages violence, 
spreads lies from foreign enemies, or defrauds people, a fire 
in a crowded theatre, that that is not protected.
    But this freedom should be nonpartisan. It is, you know, 
whether you are Republicans or Democrats are in power, we 
should all remain united in stopping these genuine threats to 
the fundamental civil rights of our society. People in this 
country should be free to speak their minds without pressure, 
without censorship. Not from government, not from government 
agencies or policies, not from companies acting under political 
influence.
    What worries me is that some claim to defend free speech 
only when it helps their political party and ignore it when it 
silences others. And I think it is worth reiterating that we 
are not here to pick sides, it is to make sure that we protect 
everyone's right to speak freely no matter who they are, what 
they believe, or what they are saying.
    Let me start just by talking a little bit about campus. You 
know, I went to a small liberal arts college in Middletown, 
Connecticut, the famous Wesleyan University, and they, like 
every school had to navigate a lot of this in the last couple 
years. We have seen an increase in people calling for imposing 
bans on peaceful organizing related to issues such as the war 
in Gaza, or Black Lives Matter.
    I think we also need to recognize our duty to protect the 
rights of conservative views that are expressed on college 
campuses. I know that Wesleyans worked very hard to make sure 
that they get both sides. But not everyone has. And whether we 
agree or disagree with each other, our right to that freedom of 
speech should be defended loudly and consistently. I think as 
long as we all feel that our safety is protected from threats 
of violence, of unconscionable violence.
    So let me start, Mr. Berenson, regardless of ideology, as 
long as individuals or groups are not inciting violence with 
the intent to harm others, should they not have the same rights 
to free speech?
    Mr. Berenson. Yes.
    Senator Hickenlooper. Not a very complicated question, but 
it is one of those ones that I feel like the more times you can 
ask it on the record, each time you do that, it builds a little 
bit of a better foundation.
    Mr. Davis, you have defended conservative speech online. 
Would you extend that same defense to college students 
expressing their views about the U.S. foreign policy, or 
calling for racial justice, if their speech was censored by a 
state government?
    Mr. Davis. Yes, I do not think American citizens should be 
subjected to censorship by their government anywhere for any 
reason.
    Senator Hickenlooper. I just want to make sure that is on 
the record. I was pretty sure what that answer would be. You 
know, we have seen some disinformation campaigns from foreign 
governments. U.S. Government under both Republicans and 
Democrats have worked hard to limit, counter foreign 
propaganda--and counter foreign propaganda, they are especially 
important. These efforts are especially important when it comes 
to stopping these disinformation campaigns that, oftentimes, 
are trying to interfere in our elections.
    Under the first Trump administration, the FCC even proposed 
to require the mandatory disclosure of all foreign sponsored 
content broadcast over TV or radio. Again, there are some that 
argue that that disclosure would in fact be a form of 
limitation. I am not saying that myself.
    Now, Mr. Berenson, again, would you support the government 
having zero communication with companies about foreign 
disinformation campaigns that could affect U.S. elections or 
public safety?
    Mr. Berenson. I mean, I have not really thought about that. 
Zero? I do not know. There might be a time when it would be 
reasonable. But I mean, you said foreign, right?
    Senator Hickenlooper. Yes.
    Mr. Berenson. So the First Amendment does not--is not 
implicated. The problem as we have seen in the last 10 years, 
it is very easy to go down a slippery slope and you start 
interfering in American speech. So I think you have to be very 
careful.
    Senator Hickenlooper. That is where that question comes 
from, especially when sometimes that disinformation is our 
foreign rivals or adversaries of Iran, Russia, China.
    Last question, Mr. Volokh, is there not a difference 
between coercive threats and agencies actually sharing factual 
information about foreign disinformation campaigns? And I think 
one example of this would be Russia's 2016 interference 
efforts. And would you recommend the U.S. Government simply 
stop investigating foreign interference on our elections 
altogether, or you know, if we were to do that, what would that 
do? Would that help or harm our democracy?
    Mr. Volokh. So there is a difference between coercion and 
kind of other non-coercive communication. The coercion would be 
a First Amendment violation. The others may or may not be, 
depending I think on how systemic they are. I do think that 
indeed we have seen lots of situations throughout American 
history where attempts to try to suppress foreign influence 
have turned into attempts to suppress domestic dissent.
    Including in the examples you gave of some people who are 
trying to suppress, I think wrongly trying to suppress anti-
Israel speech on campuses are arguing: Oh, these people are the 
cats' paws of Hamas and such.
    So I do think that, even to the extent it is permissible 
for the government to communicate with the platforms, I think 
it is important that there be as much transparency as is 
possible consistently with national security, and that it is 
especially dangerous when they are trying to--where the 
government is trying to do that and then nobody finds out about 
it for years or until somebody manages to break the log jam in 
a lawsuit using discovery.
    Senator Hickenlooper. Thank you. Mr. Chair, if I can ask 
one more question?
    Senator Schmitt. Sure.
    Senator Hickenlooper. It will just be a yes/no, because 
this is one that I was--never really followed I had--until I 
was partners with a woman, remarkable woman named Joyce Meskis, 
had a bookstore in Denver called the Tattered Cover, and she 
was a great defender of free speech, and she looked at it in 
the--in that sense of: Your speech is part of what you read, 
and you should be able to read whatever you want without 
government interference or knowing about it.
    And there was a domestic terrorist who had blown up--had a 
bomb. They were pretty sure that he had purchased the book on 
how to make this bomb at her bookstore. And she refused to give 
the information over what her customers had purchased. And I 
just wanted to see with each of you whether you think that is--
in that situation whether that is appropriate or not? And that 
is it is pretty much what it was. They wanted to get--find out 
whether this guy had bought that book from the bookstore as 
part of the case. And she said: You do not need that case. You 
got them on a million other things. This is a freedom of 
information issue.
    Yes, so I will start with you, Mr. Volokh.
    Mr. Volokh. Yes, so as I recall, I think she prevailed in 
that particular case. I am not sure that the court got it right 
there. As a general matter if--especially if there is probable 
cause and a warrant, all sorts of information may need to be 
turned over, and I am not sure there should be a categorical 
prohibition on disclosure of that information, especially when 
there is probable cause in a warrant.
    Mr. Berenson. I think that is a very smart answer, and I 
will just go with it.
    [Laughter.]
    Mr. Davis. Yes, I am not familiar with the facts of that 
case obviously as you are. I think that is a pretty complicated 
one. So I am going to have to decline on that one because I 
just do not have enough information. But that that is a, that 
is a tricky one.
    Senator Hickenlooper. You guys would not make very good 
senators. You know, all of our cases are pretty tricky.
    Mr. Kimmelman. Senator, I can understand the sentiment that 
she expressed and why she did it. I think I agree with Mr. 
Volokh, if there is a real legal cause for that information be 
handed over, the government has a right to it.
    Senator Hickenlooper. Well, I guess----
    Senator Schmitt. I think they dodged pretty well, Senator. 
They would make good senators.
    Senator Hickenlooper. Yes. I am pretty sure. You are 
exactly right--that means they would be excellent material for 
senators.
    Senator Schmitt. Yes. They pivoted.
    Senator Hickenlooper. I think that the Supreme Court 
obviously did support her and that this was part of the free 
speech that should be protected. And I guess you can, those 
most of you disagreed with that. So you can feel some comfort 
that precedence does not seem to be that all powerful in the 
present court. So there is a--certainly a chance in a similar 
situation we might get a different ruling.
    Senator Schmitt. Thank you. Thank you, Senator.
    Senator Hickenlooper. I yield back
    Senator Schmitt. Thank you, all. I want to thank all the 
witnesses for their testimony here today.
    Senators will have until the close of business on October 
15 to submit questions for the record. The witnesses will have 
until the close of business on October 29 to respond to those 
questions.
    And with that, that concludes today's hearing. The 
Committee stands adjourned.
    [Whereupon, at 12:33 p.m., the hearing was adjourned.]

                            A P P E N D I X

        The Leadership Conference on Civil and Human Rights
                                                    October 8, 2025

Hon. Ted Cruz,
Chair,
Committee on Commerce, Science, and Transportation,
U.S. Senate,
Washington, DC.

Hon. Maria Cantwell,
Ranking Member,
Committee on Commerce, Science, and Transportation,
U.S. Senate,
Washington, DC.

Dear Chair Cruz and Ranking Member Cantwell,

    On behalf of The Leadership Conference on Civil and Human Rights, a 
coalition charged by its diverse membership of more than 240 national 
organizations to promote and protect the rights of all persons in the 
United States, and the undersigned co-chairs of our Media/
Telecommunications Task Force, we appreciate the committee's attention 
to the critical issue of government overreach and threats to free 
expression guaranteed by the Constitution. The First Amendment serves 
as the bedrock of American democracy, and vigilance against government 
overreach is essential to preserving our constitutional freedoms. For 
these reasons, we respectfully request that you follow this hearing 
with one conducting oversight of the current Federal Communications 
Commission (FCC) and its commissioners. We also ask for this letter to 
be entered into the record of the Senate Committee on Commerce, 
Science, and Transportation hearing titled ``Shut Your App: How Uncle 
Sam Jawboned Big Tech Into Silencing Americans.''
The Supreme Court Recently Rejected Claims of Unconstitutional 
        ``Jawboning'' by the Prior Administration, Including 
        Allegations Against CISA.
    This hearing claims to examine a ``censorship campaign conducted in 
secret by the Biden administration's Cybersecurity and Infrastructure 
Security Agency (CISA).'' Just last year, the Supreme Court examined 
similar allegations in Murthy v. Missouri (2024) and rejected them.
    In Murthy, plaintiffs--including two states and five social media 
users--alleged that Biden administration officials, including CISA, the 
White House, the Surgeon General, and the Center for Disease Control 
(CDC), pressured social media platforms to censor speech about COVID-19 
and election-related topics in violation of the First Amendment. The 
District Court issued a preliminary injunction against multiple 
agencies including CISA, and the Fifth Circuit affirmed.
    The Supreme Court reversed 6-3, holding that plaintiffs lacked 
standing because they failed to establish that their injuries were 
fairly traceable to government conduct or that an injunction would 
redress their harms. Writing for the majority, Justice Coney Barrett 
emphasized that the extensive factual record--spanning over 26,000 
pages--did not support the conclusion that government communications 
actually coerced platforms into content moderation decisions.
    The Court made several critical factual findings that undermined 
plaintiffs'' claims of coercion. First, ``the platforms had independent 
incentives to moderate content and often exercised their own 
judgment.'' Second, and most significantly, ``the platforms began to 
suppress the plaintiffs' COVID-19 content before the defendants' 
challenged communications started.'' The Court found that this is 
timeline undermined any inference that government pressure, rather than 
platforms' independent editorial policies, drove moderation decisions. 
As Justice Coney Barrett explained, this ``complicates the plaintiffs' 
effort to demonstrate that each platform acted due to `government-
coerced enforcement' of its policies, rather than in its own 
judgment.''
    The Court further found that by the time plaintiffs filed suit in 
August 2022, ``the frequent, intense communications that took place in 
2021 between the Government defendants and the platforms had 
considerably subsided.'' Without evidence of ongoing pressure, the 
Court concluded that there was no basis to conclude that future content 
moderation would be traceable to government action rather than 
platforms' independent editorial choices. The Court noted that ``the 
available evidence indicates that the platforms have continued to 
enforce their policies against COVID-19 misinformation even as the 
Federal Government has wound down its own pandemic response measures.''
    Critically, the Murthy decision distinguished between government 
communications--even strong or critical ones--and unconstitutional 
coercion. The Court recognized that government officials may express 
views about misinformation and even ``speak with the platforms about 
COVID-19 and election-related misinformation,'' without violating the 
First Amendment. The core of this analysis is whether such 
communications cross the line into coercion that transforms private 
editorial decisions into state action. The Court held that the 
extensive factual record before it did not meet this standard.
    In Murthy, the Supreme Court examined claims similar to those at 
the heart of this hearing. After exhaustive fact-finding, the Court 
concluded that the evidence did not establish the causal link required 
to show unconstitutional coercion, finding instead that platforms acted 
on independent incentives, began content moderation before most 
government communications occurred, and continued their policies after 
government engagement ceased.
    The Court's framework makes clear that strong government criticism 
of platform policies, or even requests for policy changes, do not 
constitute ``jawboning'' absent concrete evidence that government 
pressure, rather than platforms' own editorial judgment, drove specific 
moderation decisions.
The First Amendment Protects Content Moderation Decisions by Platforms 
        and Prevents Government Intrusions that Suppress Individual 
        Freedom of Expression.
    This hearing's framing inverts the actual threat of jawboning and 
the continued undermining of First Amendment rights that people in the 
U.S. face today. While the committee examines the actions of a previous 
administration no longer able to jawbone, the current administration is 
waging an unprecedented campaign of government coercion against private 
actors' constitutionally protected rights to engage in content 
moderation and editorial judgement.
    Since inauguration day, the President has used private lawsuits to 
extract nearly $60 million in settlements from social media platforms 
and over $30 million from major broadcast media outlets; the 
administration has simultaneously been attempting to criminalize 
otherwise protected speech by threatening prosecutions and political 
retaliation.\1\ These actions fall squarely within this Committee's 
jurisdiction and demand immediate oversight, investigation, and 
accountability for these ongoing abuses.
---------------------------------------------------------------------------
    \1\ Charlie Warzel, ``YouTube Bends the Knee,'' The Atlantic (Oct. 
1, 2025), https://www.theatlantic.com/technology/2025/10/youtube-trump-
settlement/684431/?gift=YyWH8Vk
lYl_6f2ICNsEnCaezGBz2MZZ0fzSx_iY8nfE; Meg James, ``After CBS and ABC's 
Trump Settlements, Democrats Want to Curb Presidential Library Gifts,'' 
Los Angeles Times (July 16, 2025), https://www.latimes.com/
entertainment-arts/business/story/2025-07-16/cbs-abc-trump-payouts-
qatar-jet-proposed-curbs-library-gifts.
---------------------------------------------------------------------------
    Private companies--including social media platforms, broadcasters, 
and publishers--possess their own First Amendment rights to establish 
and enforce community standards, moderate content, and make editorial 
decisions about what speech to host or amplify on their platforms. The 
Supreme Court has repeatedly and recently affirmed these principles.
    In Moody v. NetChoice (2024), the Court held that platforms engage 
in constitutionally protected speech activity when they exercise 
editorial discretion, and that the government cannot require platforms 
to ``carry and promote [] speech they would rather discard or 
downplay.'' The Court explicitly rejected arguments that government can 
dictate platforms' content moderation to achieve ideological balance, 
noting that ``it is no job for government to decide what counts as the 
right balance of private expression.''
    Similarly, in National Rifle Association v. Vullo (2024), the Court 
unanimously held that government officials cannot use regulatory 
authority to coerce private entities into suppressing speech, warning 
that officials cross into impermissible coercion when their conduct 
``could be reasonably understood to convey a threat of adverse 
government action in order to punish or suppress speech.''
Recent Activity and Statements by the Trump Administration Constitute a 
        Campaign of Coercive Intrusion and Control that Violate the 
        First Amendment.
    The Trump administration's ongoing campaign against companies' 
content moderation and editorial decisionmaking runs afoul of the 
standard for impermissible government coercion set out in NRA v. Vullo. 
In September 2025, YouTube settled with President Trump for $24.5 
million over its decision to suspend his account following January 6, 
2021--joining Meta ($25 million) and X ($10 million) in paying nearly 
$60 million collectively for enforcing their own community standards 
during a national crisis.\2\
---------------------------------------------------------------------------
    \2\ Charlie Warzel, ``YouTube Bends the Knee,'' The Atlantic (Oct. 
1, 2025), https://www
.theatlantic.com/technology/2025/10/youtube-trump-settlement/684431/
?gift=YyWH8VklYl_6f2
ICNsEnCaezGBz2MZZ0fzSx_iY8nfE.
---------------------------------------------------------------------------
    These settlements represent precisely the chilling effect the First 
Amendment forbids: private companies' forced acquiescence in response 
to a ``threat of'' (or actual) ``adverse government action'' that 
interferes with and punishes private actors for exercising their 
editorial judgment as permitted by the First Amendment. This chilling 
effect extends across the entire media ecosystem, from social media 
platforms to broadcast networks to publishers, creating an environment 
of threat or undue government pressure in which companies make 
editorial decisions based on government pressures rather than their own 
standards, business model, users' safety, or the public interest.
    Recent statements by top U.S. Department of Justice (DOJ) officials 
further showcase how this administration is perpetuating unlawful 
overreach, violating principles of freedom of expression. After the 
murder of Charlie Kirk, Attorney General Pam Bondi has threatened to 
prosecute individuals and even businesses for ``hate speech''--speech 
that is constitutionally protected from government sanction--while 
simultaneously pressuring companies to abandon their own voluntary 
efforts to moderate such content.\3\ This incoherent approach punishes 
the exercise of free speech by individuals and companies alike, 
undermining constitutional protections and boundaries while expanding 
government control and suppressing free expression.
---------------------------------------------------------------------------
    \3\ Giselle Ruhiyyih Ewing, `` `That is Not the Law': Bondi 
Promised to Target `Hate Speech.' She's Facing Backlash From All 
Corners.,'' Politico (Sept. 16, 2025), https://www.politico.com/news/
2025/09/16/pam-bondi-first-amendment-hate-speech-prosecution-00566424.
---------------------------------------------------------------------------
    Social media platforms have substantial legitimate interests--
indeed, even responsibilities--in moderating hate speech, preventing 
the organization of violent extremist groups, and limiting the 
amplification of content that harms users and degrades the quality of 
discourse. Unlike government actors that are constrained by the First 
Amendment's prohibition on censoring hate speech, private platforms may 
permissibly decide not to host or amplify hate speech, inauthentic or 
misleading content, or extremist organizing. These editorial decisions 
serve multiple critical purposes: they maintain a platform's 
information ecosystem, protect users from harm, and prevent platforms 
from becoming vectors for radicalization and real-world violence.
Coerced Demoderation Extracts Measurable Real-World Costs from 
        Communities, the Marketplace of Ideas, and American Democracy.
    The consequences of abandoning content moderation fall 
disproportionately on communities of color and other marginalized 
groups. When platforms have reduced appropriate content moderation, 
unmoderated spaces have become vehicles for real-world voter 
suppression, orchestrated harassment campaigns, and targeted 
disinformation that functionally silences already marginalized voices.
    As civil rights enforcement offices across Federal agencies are 
eliminated, and nondiscrimination standards are corroded, the absence 
of platform moderation exacerbates these threats. To be clear, 
harassment and disinformation do not function as mere expressions of 
viewpoints: they systematically silence communities that have 
historically faced discrimination and continue to face barriers to full 
participation in democratic discourse.
    Moreover, content moderation protects consumers from fraud and 
scams that disproportionately target communities of color. The Federal 
Trade Commission's data shows that between January 2021 and June 2023, 
losses from social media-related fraud reached $2.7 billion, with Black 
and Latino consumers more than twice as likely as white consumers to 
lose money to digital scams.\4\ Platform policies that reduce fraud and 
disinformation serve essential consumer protection functions that align 
with--rather than contradict--regulatory objectives and First Amendment 
protections.
---------------------------------------------------------------------------
    \4\ Emma Fletcher, ``Social Media: A Golden Goose for Scammers,'' 
Federal Trade Commission (Oct. 6, 2023), https://www.ftc.gov/news-
events/data-visualizations/data-spotlight/2023/10/social-media-golden-
goose-scammers.
---------------------------------------------------------------------------
    The consequences of demoderation have become evident. Users of X 
(formerly Twitter), following the platform's adoption of minimal 
content moderation policies and elimination of fact-checking, have 
experienced widely reported increases in hate speech, harassment, and 
extremist content. The platform has seen significant advertiser 
departures and user migration to alternative platforms.\5\ This 
degradation demonstrates why platforms historically invested in content 
moderation--not because the government forced them to, but because 
maintaining quality standards is essential to user safety and to 
product quality and viability.
---------------------------------------------------------------------------
    \5\ Michael Jensen, ``Hate Speech on X Surged for at Least 8 Months 
After Elon Musk Takeover--New Research,'' The Conversation (Feb. 12, 
2025), https://theconversation.com/hate-speech-on-x-surged-for-at-
least-8-months-after-elon-musk-takeover-new-research-249603
---------------------------------------------------------------------------
    Government jawboning in its most pernicious form is the current 
distortion and unlawful weaponization of legal precedent and 
established constitutional norms to pressure private actors to abandon 
editorial standards altogether while also attempting to criminalize 
otherwise protected speech. If this Committee is concerned about 
government threats to free speech and editorial independence, this 
administration's ongoing campaign of corporate and individual 
intimidation and capitulation-seeking behavior demands immediate 
oversight and investigation.
FCC Chair Brendan Carr's Actions Warrant Scrutiny by the Full Commerce 
        Committee.
    Much has already been said about FCC Chair Brendan Carr's comments 
to American Broadcasting Company (ABC) affiliates urging them to inform 
ABC that they would not carry Jimmy Kimmel Live and highlighting the 
power the FCC has over the broadcasting licenses of the affiliates.\6\ 
First amendment experts pointed to Carr's rhetoric and the subsequent 
(temporary) removal of Kimmel's show as a textbook example of an undue 
and violative form of pressure,\7\ and highlighted the many ways in 
which the FCC has attempted to police speech in the name of the public 
interest (both in the issuance of broadcast licenses and the approval 
of mergers).\8\
---------------------------------------------------------------------------
    \6\ Press Release, ACLU, ACLU Responds to Trump Administration Move 
Censoring Jimmy Kimmel (Sept. 17, 2025), https://www.aclu.org/press-
releases/aclu-responds-to-trump-administration-move-censoring-jimmy-
kimmel. 
    \7\ Anna Branigin, ``How Cancel Culture Came for Everyone,'' 
Washington Post (Oct. 1, 2025), https://www.washingtonpost.com/style/
power/2025/10/01/cancel-culture-kimmel/.
    \8\ Ted Johnson, ``Brendan Carr's Threats On Networks May Be 
``Jawboning,'' And Courts Don't Like It, Legal Experts Say'' Deadline 
(Sept. 19, 2025), https://deadline.com/2025/09/fcc-brendan-carr-
jawboning-jimmy-kimmel-1236549243/; Tom Wheeler, ``Trump's CBS Lawsuit 
Ties Media Freedom to FCC's Regulatory Power,'' Brookings (Feb. 19, 
2025), https://www.brook
ings.edu/articles/trumps-cbs-lawsuit-ties-media-freedom-to-fccs-
regulatory-power/.
---------------------------------------------------------------------------
    Underlying all of this is also Nexstar's pending merger before the 
FCC and the upcoming changes to its existing media ownership rules, 
necessary for the merger to be permitted under current law.\9\ This 
recent behavior by the Chair was so egregious that many members of 
Congress on both sides expressed deep concern,\10\ and some even called 
for Carr's removal as Chair.\11\
---------------------------------------------------------------------------
    \9\ Keith Collins and Raj Saha, ``How a TV Merger Raised the 
Pressure on ABC to Suspend Kimmel,'' New York Times (Sept. 19, 2025), 
https://www.nytimes.com/interactive/2025/09/19/business/media/abc-
nexstar-kimmel.html.
    \10\ Anthony Adragna, John Hendel, and Gabby Miller, `` `Be Very 
Careful:' Some in the GOP Balk at Kicking Kimmel Off TV,'' Politico 
(Sept. 18, 2025), https://www.politico.com/news/2025/09/18/gop-
lawmakers-come-out-against-the-fccs-role-in-kimmel-axing-00572140.
    \11\ Press Release, Democratic Leader Hakeem Jeffries, Whip 
Katherine Clark, Caucus Chair Pete Aguilar, Caucus Vice Chair Ted Lieu, 
Assistant Leader Joe Neguse and DCCC Chair Suzan DelBene, Joint 
Leadership Statement on the Suspension of Jimmy Kimmel (Sept. 18, 
2025), https://democraticleader.house.gov/media/press-releases/joint-
leadership-statement-suspension-jimmy-kimmel.
---------------------------------------------------------------------------
    We also have serious concerns about the way in which 
telecommunications companies have been pressured by FCC leadership into 
dropping their diversity, equity, and inclusion programs to ensure 
their mergers are approved.\12\ Both T-Mobile and Verizon had pending 
mergers before the FCC that were approved within days of sending 
letters to Chair Carr announcing the end of the programs. Despite plain 
civil rights mandates and an abject failure to meet them, the FCC 
required many companies to eliminate their programs that aimed to 
ensure fair treatment of and equal opportunity for women, people of 
color, people with disabilities, and the LGBTQ community in order for 
their mergers to be approved.
---------------------------------------------------------------------------
    \12\ Brit Morse, ``The FCC Takes on a New Role: DEI Regulator,'' 
Fortune (July 17, 2025), https://fortune.com/2025/07/17/federal-
communications-commission-new-role-dei-regulator/.
---------------------------------------------------------------------------
    Chair Carr has shown a pattern of complete disregard for the First 
Amendment and a willingness to abuse the FCC's authority to further 
this administration's authoritarian agenda. All of the above actions 
are part of a larger pattern of behavior at the FCC: disregard for the 
law and the will of Congress. This warrants further investigation by 
the Commerce Committee, and we strongly urge you to follow-up this 
hearing with one conducting oversight of the current FCC and its three 
commissioners.
    We stand ready to work with Congress on policies that will protect 
civil rights, prevent unlawful discrimination, and advance equal 
opportunity. Should you require further information or have any 
questions regarding this issue, please feel free to contact Jonathan 
Walter, senior policy counsel, at [email protected].
            Sincerely,
                    The Leadership Conference on Civil and Human Rights

                                                               UnidosUS

                         United Church of Christ Media Justice Ministry
                                 ______
                                 
 Prepared Statement of Writers Guild of America West and Writers Guild 
                            of America East
  Media Consolidation Enables Censorship and is a Threat to Workers, 
                    Consumers, and American Culture
    The Writers Guild of America West (WGAW) and Writers Guild of 
America East (WGAE) appreciate the opportunity to submit this statement 
for the record concerning the hearing entitled ``Shut Your App: How 
Uncle Sam Jawboned Big Tech into Silencing Americans'' on behalf of our 
membership. WGAW is a labor organization representing more than 11,000 
professional writers of films, television and streaming series, and 
news programming. WGAE is a labor union of more than 7,500 members 
working in film, television, news, podcasts and online media.
    For decades, the Guilds have called attention to the threat that 
concentrated market power in media poses to diversity of content and 
variety of viewpoints, in the context of mergers, antitrust policy, and 
broadcast and Internet regulations. Our members are directly affected 
by the lack of competition in media--a consolidated handful of 
employers have tremendous power to pressure writer compensation and 
working conditions and to gatekeep what stories can be seen in 
theaters, on television and on streaming services.
    Recent events have illustrated how easily this concentration of 
power transforms into direct censorship. ABC's decision to stop airing 
Jimmy Kimmel Live! after pressure from the Trump Administration and 
Nexstar Media Group followed Paramount's cancellation of The Late Show 
with Stephen Colbert during the Federal government's review of the 
Paramount-Skydance merger.\1\ Still more consolidation looms on the 
horizon. Powerful and consolidated gatekeepers already exercise 
considerable control over free speech by deciding what programming 
reaches Americans and unless consolidation in this industry is 
addressed, censorship of Americans by large conglomerates and the 
Federal government will remain unchecked.
---------------------------------------------------------------------------
    \1\ Press Release, WGA Statement on ABC's Decision to Pull Jimmy 
Kimmel Live! WGAW (Sept. 17, 2025), https://www.wga.org/news-events/
news/press/2025/wga-statement-on-abc-decision-to-pull-jimmy-kimmel-
live.
---------------------------------------------------------------------------
Mergers have Consolidated Control over Media
    Deregulation and antitrust underenforcement over the last few 
decades have allowed for waves of consolidation in the media industry, 
leaving just a handful of major studios with control over the 
marketplace. Over the last two decades, more than $435 billion worth of 
mergers and acquisitions have been completed in media production or 
distribution.\2\ These mergers have increased the power of corporations 
to the detriment of writers, viewers, and competition.
---------------------------------------------------------------------------
    \2\ WGAW, Broker Promises: Media Mega-Mergers and the Case for 
Antitrust Reform (2021), https://www.wga.org/uploadedfiles/
news_and_events/public_policy/broken-promises-merger-report.pdf.
---------------------------------------------------------------------------
    After the Disney-Fox merger, for example, Disney closed the 
competing Fox animation studio, pulled back content it had licensed to 
Netflix, banned Netflix from advertising on its television 
entertainment networks, and pressed creators and other workers to 
forego sharing in future licensing revenue on Disney shows. Disney's 
serial acquisitions of Pixar, Marvel, Lucasfilm, and Fox have reduced 
innovative development in favor of focusing on franchise films, 
reducing variety and choice at the theater. The company now owns two of 
the four largest streaming services in the U.S., Disney+ and Hulu, and 
has announced plans to combine them. After the Warner-Discovery merger, 
the company canceled, pulled, or wrote off $2 billion in content, 
including numerous projects created by or about people of color, and 
laid off hundreds of workers. WarnerMedia and Discovery are now 
essentially up for sale as the pre-merger companies; yet another in a 
series of mergers that purported to create better competitors, but 
instead result in merged entities burdened by debt and focused on 
rationalizing their disastrous business decisions by cutting costs.
Streaming is Accelerating the Problems of a Consolidated Media 
        Landscape
    In recent years, streaming video has become the dominant 
distribution platform for content while also becoming increasingly 
vertically integrated. In the 2024-2025 television season, 78 percent 
of original scripted streaming series were distributed by four 
companies, Netflix, Disney, Amazon and Apple.\3\ The entertainment 
industry's major employers also combine content production and 
distribution arms in order to self-supply their own content globally on 
their affiliated streaming services. In the 2024-2025 television 
season, nearly three-quarters of online scripted content on the major 
streaming platforms was self-supplied.\4\ This market structure 
forecloses competition from independent producers and distributors, 
enables monopsony power over writers and other industry workers, and 
gives conglomerates outsized control over what content reaches 
audiences.
---------------------------------------------------------------------------
    \3\ Writers Guild of America West Internal Data, 2025 (on file with 
WGAW) (based on WGA-covered scripted series).
    \4\ The major streaming platforms are Amazon Prime Video, Apple 
TV+, Disney+, HBO Max, Hulu (folding into Disney+), Netflix, Paramount+ 
and Peacock. Writers Guild of America West Internal Data, 2025 (on file 
with WGAW) (based on WGA-covered scripted series).
---------------------------------------------------------------------------
    In the current streaming landscape, independent producers must 
compete with affiliated studios to sell content to the studios' 
streaming services, leaving them with few opportunities for accessing 
consumers. Meanwhile, a new competitor in streaming distribution would 
have difficulty licensing the third-party premium content it needs to 
offer a competitive service. The Disney-Fox and AT&T-Time Warner 
mergers, for instance, were both immediately followed by those 
companies withdrawing their content from competing services like 
Netflix and Amazon in favor of launching Disney+ and HBO Max.\5\ And in 
order to reach the end consumer, new streaming distribution entrants 
must strike deals with platform gatekeepers Amazon Fire TV, Roku, or 
Apple TV--which together control two-thirds of the U.S. connected TV 
market\6\--to have their apps available on the services, a barrier that 
reportedly inhibited the launches of HBO Max and Peacock.\7\ This 
market structure and the mergers that created it raise substantial 
barriers to entry, reduce innovation in content production, and 
increase the ability of gatekeepers to impose their own restrictions on 
what content gets made--while making further consolidation more likely.
---------------------------------------------------------------------------
    \5\ See, e.g., Michelle Castillo, Disney Will Pull Its Movies From 
Netflix and Start Its Own Streaming Services, CNBC (Aug. 8, 2017), 
https://www.cnbc.com/2017/08/08/disney-will-pull-its-movies-from-
netflix-and-start-its-own-streaming-services.html; Sarah Perez, Disney+ 
Gains the Marvel Series From Netflix and New Parental Controls, 
TechCrunch (Mar. 1, 2022), https://techcrunch.com/2022/03/01/disney-
gains-the-marvel-series-from-netflix-and-new-parental-controls/; Ben 
Munson, HBO Max Expects Subscriber Impact From Amazon Channels Exit, 
Fierce Video (Aug. 11, 2021), https://www.fiercevideo.com/video/hbo-
max-expects-subscriber-impact-from-amazon-channels-exit.
    \6\ Press Release, Pixalate's Q2 2025 Global Connected TV Device 
Market Share Reports: Roku Leads in North America (37 percent) and 
LATAM (45 percent), Samsung No. 1 in EMEA (33 percent), Xiaomi Leads in 
APAC (24 percent) (2025), https://finance.yahoo.com/news/pixalate-q2-
2025-global-connected-143100935.html.
    \7\ HBO Max and Peacock customers were unable to access the new 
streaming services through Amazon devices when they launched in 2020 
because the companies had not reached agreement. Peacock and HBO's 
disputes reportedly stemmed from executives' desires to keep their 
streaming services outside of Amazon Channels to retain control of the 
user experience and viewership data. News commentary suggested that the 
lack of Amazon Fire carriage notably slowed subscriber growth at these 
services, and when HBO Max finally reached a deal with Amazon months 
later, the terms included an extension of WarnerMedia's contract with 
Amazon Web Services, its cloud computing platform.
---------------------------------------------------------------------------
    Streaming's dominant employers have also used their leverage to 
push down writers' pay. In 2023, writers went on strike for nearly five 
months to improve compensation and employment terms as practices such 
as short-term, more precarious employment and caps on experienced 
writer compensation had spread between employers to become 
``standard.'' The lack of competition and vertical integration has also 
led to disputes among the bargaining parties in the period between 
contract negotiations. For example, the WGAW has collected millions in 
underpayment from Paramount\8\ and Netflix\9\ for undervaluing 
``imputed'' license fees to vertically-integrated streaming services, 
and has filed related claims against Disney and NBCUniversal. Each of 
these disputes stems directly from the increasing consolidation of the 
media companies.
---------------------------------------------------------------------------
    \8\ Cynthia Littleton, WGA Sets $3.4 Million Settlement With CBS 
for All Access Streaming Residuals, Variety (Apr. 15, 2021), https://
variety.com/2021/tv/news/wga-cbs-streaming-settlement-all-access-
1234952956/.
    \9\ Katie Kilkenny, Writers Guild Arbitration With Netflix Yields 
$42M in New Residuals for Members, The Hollywood Reporter (Aug. 4, 
2022), https://www.hollywoodreporter.com/business/business-news/wga-
netflix-residuals-42-million-writers-1235192877/.
---------------------------------------------------------------------------
    In the streaming market, instead of dynamic competition, we also 
see all the major firms raising prices and reducing content spending in 
parallel, leaving consumers to pay more for less, hallmarks of a 
concentrated market. And despite these already anticompetitive 
conditions, Wall Street continues to call for further consolidation. 
More mergers will leave even fewer firms in control of what content can 
reach audiences, and diminished variety in media's marketplace of 
ideas. And as the suspension of Jimmy Kimmel Live! and cancellation of 
The Late Show of Stephen Colbert illustrate, the lack of competition 
can easily facilitate explicit censorship.
Congress Must Act
    Over the past few months, both Comcast-NBCUniversal and Warner 
Bros. Discovery have announced plans to spin off their linear networks 
to better position themselves for future M&A transactions. The newly 
combined Paramount-Skydance, immediately after that merger's 
conclusion, is exploring a bid for all of the assets of Warner Bros. 
Discovery, which would combine two major streaming services, movie and 
television studios, and a suite of television networks under a single 
owner. Absent government intervention, more harmful mergers are on the 
horizon as each merger spurs reactive consolidation among the remaining 
firms. But even the existing level of consolidation and vertical 
integration in the media industry is unacceptable and demands scrutiny, 
as we have recently seen it put free speech at risk. Congress must 
explore creative solutions that address the current level of 
consolidation, including limits on the ability of streaming services to 
own the content on their platforms, which was a condition of the 
Financial Interest and Syndication rules imposed on the broadcast 
networks when they held similar levels of control over content 
distribution. Failing to act will allow streaming services to dictate 
what stories are told, and permit media conglomerates to exercise their 
economic power as political power.
                                 ______

[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]                                 
                                 ______
                                 
      Response to Written Questions Submitted by Hon. Ted Cruz to 
                             Eugene Volokh
    Question 1. Does the First Amendment apply to the information 
Americans are permitted to receive and not just the content they can 
express?
    Answer. Yes. See, e.g., Va. State Bd. of Pharmacy v. Va. Citizens 
Consumer Council, Inc., 425 U.S. 748, 756 (1976) (concluding that 
commercial speech is protected because ``protection afforded is to the 
communication, to its source and to its recipients both''); id. at 757 
(``[I]n Procunier v. Martinez, 416 U.S. 396, 408-409 (1974), where 
censorship of prison inmates' mail was under examination, we thought it 
unnecessary to assess the First Amendment rights of the inmates 
themselves, for it was reasoned that such censorship equally infringed 
the rights of noninmates to whom the correspondence was addressed.''); 
First Nat'l Bank of Boston v. Bellotti, 435 U.S. 765, 775-76, 783 
(1978) (concluding that corporate speech is protected ``based not only 
on the role of the First Amendment in fostering individual self-
expression but also on its role in affording the public access to 
discussion, debate, and the dissemination of information and ideas''); 
Lamont v. Postmaster Gen., 381 U.S. 301, 305, 307 (1965) (relying on 
``the addressee's First Amendment rights'' rather than the sender's, 
where the sender was a foreign government); see also id. at 307-08 
(Brennan, J., concurring) (stressing that it's not clear whether the 
First Amendment protects ``political propaganda prepared and printed 
abroad by or on behalf of a foreign government,'' but concluding that 
the law was unconstitutional because it violated the recipients' 
``right to receive'' information, regardless of the senders' rights to 
speak).

    Question 2. Does the First Amendment apply to artificial 
intelligence?
    Answer. I think the First Amendment precludes the government from 
restricting the output of AI programs, because that would unduly 
interfere with Americans' right to receive information (and Americans' 
right to use the AI to help craft their own messages). See Eugene 
Volokh, Mark A. Lemley & Peter Henderson, Freedom of Speech and AI 
Output, 3 J. Free Speech L. 651 (2023).

    Question 3. What are the First Amendment and free speech 
implications of government attempts to alter content generated by 
artificial intelligence to address alleged ``bias'' or to pressure 
artificial intelligence companies to set up processes to moderate or 
eliminate alleged ``disinformation,'' as well as ``offensive'' or 
``objectionable'' content?
    Answer. I think this would violate the First Amendment, just as it 
would be unconstitutional for the government to restrict ``bias,'' 
``disinformation,'' or ``offensive'' or ``objectionable'' content in 
newspapers. See, e.g., Miami Herald Publishing Co. v. Tornillo, 418 
U.S. 241 (1974) (bias); New York Times Co. v. Sullivan, 376 U.S. 254, 
288 (1964) (disinformation about the government); United States v. 
Alvarez, 567 U.S. 709 (2012) (plurality opin.) (disinformation 
generally); id. at 731-32 (Breyer, J., concurring in the judgment) 
(disinformation about ``philosophy, religion, history, the social 
sciences, the arts, and the like''); id. at 751 (Alito, J., dissenting) 
(disinformation ``about philosophy, religion, history, the social 
sciences, the arts, and other matters of public concern''); Hustler 
Magazine, Inc. v. Falwell, 485 U.S. 46 (1988) (offensive or 
objectionable content).

    Question 4. What should I keep in mind as I craft legislation to 
ensure that Americans are fully protected against government efforts to 
decide or limit what they can read?
    Answer. That substantive rules require procedural enforcement 
mechanisms, such as allowing people to sue the Federal government and 
officials for violating the First Amendment, just as Congress has let 
people sue state and local governments and officials.

    Question 5. What are some of the key challenges Americans face in 
court to hold the Federal government accountable for improper and 
unlawful jawboning?
    Answer. The lack of a private right of action against Federal 
officials for violating First Amendment rights under color of Federal 
law, parallel to the private right of action provided as to violations 
by state and local officials under 42 U.S.C. Sec. 1983.

    Question 6. Can Congress help solve any of the challenges 
identified in the preceding question with new legislation?
    Answer. Yes, by providing a private right of action against Federal 
officials for violating First Amendment rights under color of Federal 
law, parallel to the private right of action provided as to violations 
by state and local officials under 42 U.S.C. Sec. 1983.
                                 ______
                                 
   Response to Written Questions Submitted by Hon. Maria Cantwell to 
                             Eugene Volokh
    First Amendment. Brendan Carr, the Chairman of the FCC, recently 
went on a podcast to criticize Jimmy Kimmel's comments on his late-
night talk show on ABC. He told Disney, the parent of ABC, that ``we 
can do this the easy way or the hard way.''
    And he told the licensed broadcasters that carry ABC programming 
that ``it's time for them to step up'' and stop this ``garbage.'' Just 
hours later, the biggest affiliate groups said they would preempt 
Kimmel's show, including one with a major pending merger that requires 
FCC approval. Minutes later, ABC said it would suspend Kimmel. Kimmel 
is back on the air, but the chilling effect of Brendan Carr's words 
lingers.
    As I wrote to Chairman Cruz weeks ago, we need Brendan Carr to 
answer for this attack on the free press.

    Question 1. Professor Volokh, you are a noted First Amendment 
scholar. Do you think that Carr's threats to ABC and its affiliates 
violated the First Amendment?
    Answer. Yes.

    AP and Gulf of America. President Trump tried to rename the Gulf of 
Mexico to the Gulf of America. Polls show that more than 70 percent of 
Americans oppose the idea.
    What's actually dangerous, though, is how the White House used this 
juvenile stunt to intimidate the free press. The Associated Press 
refused to go along with Trump's Orwellian attempt to make Americans 
change the name of the Gulf of Mexico.
    In retaliation, the AP was kicked out of the White House press pool 
and not allowed into the Oval Office.

    Question 1. Professor Volokh, setting aside whether the White 
House's actions technically violated the First Amendment, do you think 
that in a free society, it is appropriate for the White House to punish 
news organizations that refuse to go along with its attempts to police 
language?
    Answer. I don't believe it is appropriate, especially when the AP's 
decision went along with a long-established and broadly accepted name.
    At some point, the actions of a news outlet may become so bizarre 
or ideologically skewed that they may lead the outlet to lose 
credibility, and reasonably lead the Administration to no longer want 
to give the outlet special access to the press pool: Say, for instance, 
that the AP decided to rename the Gulf of Mexico ``the Stolen 
Indigenous People's Sea,'' or to start calling Washington, D.C. ``the 
Capital of the Great Satan.'' But of course, the AP's retaining the 
longstanding name ``Gulf of Mexico'' is very far removed from such 
hypotheticals.

    Universities. In addition to the media and law firms, President 
Trump has also targeted universities and nonprofit organizations that 
express views that he disagrees with. The administration has threatened 
to revoke non-profit status; restricted universities' ability to enroll 
international students; and canceled or paused billions of dollars in 
grant funding.
    Courts have consistently held that government officials cannot 
retaliate against individuals or entities because they disagree with 
their speech.

    Question 1. Prof. Volokh, you are a scholar of the First Amendment. 
Is it consistent with the First Amendment for the administration to 
strip the tax-exempt status or otherwise punish universities or other 
entities that have political disagreements with the administration?
    Answer. No, if the stripping or punishment were to happen because 
the universities or other entities express viewpoints that the 
administration disagrees with.

    Law Firms. Since he took office earlier this year, President Trump 
has attacked institutions that he perceives to be opposed to him. 
President Trump signed a series of executive orders targeting law firms 
that hired perceived political opponents or represented clients who 
opposed him.
    These executive orders suspend the security clearances for firm 
lawyers; deny them entrance to Federal buildings; and seek to force 
Federal contractors to end a relationship with them.

    Question 1. You are an expert on the First Amendment. Do these 
executive orders violate the First Amendment?
    Answer. Yes, considerable portions of the orders do. I signed a 
brief so arguing, Brief of Amici Curiae 353 Law Professors in Support 
of Plaintiff's Motion for Summary Judgment and for Declaratory and 
Permanent Injunctive Relief, Perkins Coie LLP v. U.S. Department of 
Justice, No. 1:25-cv-00716 (D.D.C. Apr. 2, 2025), https://
storage.courtlistener.com/recap/gov.uscourts.dcd.278290/
gov.uscourts.dcd.278290.
45.1.pdf.

    Question 2. Does the First Amendment prevent government officials 
from retaliating against political opponents for their views?
    Answer. That is complicated, because it depends on the nature of 
the retaliation. Government officials can't deny people or 
organizations generally available benefits (such as tax exemptions or 
broadly available grants aimed at promoting a diversity of private 
views) based on their viewpoints. Nor can they generally cut off 
contracts or other grants to people or organizations because of those 
people's or organizations' other speech (speech that isn't funded by 
those contracts or grants).
    But they can, for instance, refuse to appoint a political opponent 
to high office based on the opponent's views. Likewise, they can choose 
to give discretionary grants for speech that endorses certain views but 
not other views. To offer one famous example, ``When Congress 
established a National Endowment for Democracy to encourage other 
countries to adopt democratic principles, it was not constitutionally 
required to fund a program to encourage competing lines of political 
philosophy such as communism and fascism.'' Rust v. Sullivan, 500 U.S. 
173, 194 (1991).
    There are of course other possible scenarios; in some, government 
officials' viewpoint-based judgments may be unconstitutional while in 
others they may be constitutionally permissible.

    App Stores. Recently, after Attorney General Pam Bondi demanded 
that Apple remove a lawful app crowdsourcing location information from 
the App Store, Apple agreed to do so.

    Question 1. Do you think citizens sharing location information with 
each other, such as the locations of police speed checks, through an 
app, is protected speech under the First Amendment?
    Answer. It depends. At some point, it may become essentially aiding 
and abetting crime or a civil violation--basically, acting as a lookout 
for someone else--or obstruction of justice, and thus constitute 
constitutionally unprotected ``speech integral to criminal conduct.'' 
The exact boundaries of that First Amendment exception are not clearly 
settled. I wrote about this in detail at Eugene Volokh, Crime-
Facilitating Speech, 57 Stan. L. Rev. 1095 (2005), but the law has 
become still more complex since then, see Eugene Volokh, The ``Speech 
Integral to Criminal Conduct'' Exception, 101 Cornell L. Rev. 981 
(2016); United States v. Hansen, 143 S. Ct. 1932 (2023).

    Question 2. Did the Attorney General violate the First Amendment 
when she demanded that Apple remove a legal app with crowdsourced 
location data from its app store?
    Answer. If the AG threatened Apple with prosecution for removing 
such an app, then she might have violated the First Amendment, 
depending on the precise facts about just what information the app 
conveyed and under what circumstances (I'm not certain). But if the AG 
argued to Apple that the app violated Apple's own guidelines, and asked 
it to enforce those guidelines, without threatening Apple with 
prosecution or other government retaliation, then that likely didn't 
violate the First Amendment.

    Question 3. Are you aware of any instances during the Biden 
administration when the Federal government demanded that Apple or 
Google remove a legal app?
    Answer. Yes; the Protecting Americans from Foreign Adversary 
Controlled Applications Act, the statute targeting TikTok enacted 
during the Biden Administration, essentially required Apple and Google 
to remove from their app stores the TikTok app, which had hitherto been 
legal.

    Question 4. Are you aware of any instances where foreign 
governments have demanded that Apple and Google remove legal apps?
    Answer. No, but I haven't closely studied the actions of foreign 
governments.
                                 ______
                                 
   Response to Written Questions Submitted by Hon. Maria Cantwell to 
                             Gene Kimmelman
    First Amendment. Brendan Carr, the Chairman of the FCC, recently 
went on a podcast to criticize Jimmy Kimmel's comments on his late-
night talk show on ABC. He told Disney, the parent of ABC, that ``we 
can do this the easy way or the hard way.''
    And he told the licensed broadcasters that carry ABC programming 
that ``it's time for them to step up'' and stop this ``garbage.'' Just 
hours later, the biggest affiliate groups said they would preempt 
Kimmel's show, including one with a major pending merger that requires 
FCC approval. Minutes later, ABC said it would suspend Kimmel. Kimmel 
is back on the air, but the chilling effect of Brendan Carr's words 
lingers.
    As I wrote to Chairman Cruz weeks ago, we need Brendan Carr to 
answer for this attack on the free press.

    Question 1. Mr. Kimmelman, you have observed the media for decades. 
Have you ever seen quite so blatant an attempt at censorship by the 
Chair of the FCC?
    Answer. I have never seen such blatant interference in the content 
of media companies from any previous FCC Chair.

    Question 2. At the hearing, some claimed that legislators 
expressing their views about a licensed media company to the FCC, as I 
did in 2018, Senators Rubio, Scott, and Cotton did in 2022, and Senator 
Lee did in 2024, raises the same First Amendment concerns as the FCC 
Chair threatening action against a regulatee. Do you think that 
legislators expressing their views to the FCC about a licensee raises 
the same concerns as the regulator itself threatening a licensee?
    Answer. No, I believe that legislators have a right to express 
their views and propose legislation as they see fit. It is a very 
different, direct threat to the First Amendment, for the FCC to 
threaten to take action against a licensee based on the content they 
distribute.
    During the same podcast where Carr criticized Jimmy Kimmel, Carr 
also stated: ``It's the licensed TV stations that have the public 
interest standard, including those TV stations that Comcast and Disney 
own. So FCC regulatory action focuses on those individual stations.'' 
He also claimed: ``The public interest means you can't be running a 
narrow partisan circus and still meet your public interest obligations. 
It means you can't be engaging in a pattern of news distortion.''

    Question 3. Is Carr's statement that the FCC's public interest 
obligation means broadcast stations ``can't be running a narrow 
partisan circus'' correct? Why or why not?
    Answer. I don't really know what Chairman Carr was referring to, 
but the public interest test has previously been viewed as a way to 
evaluate whether a broadcaster is meeting community needs. It is hard 
to imagine that presentation of a set of views of interest in a 
community is somehow outside the scope of the public interest. The FCC 
has previously refrained from cataloging ideas as ``partisan'' just for 
presenting a particular point of view, to protect the First Amendment 
rights of their licensees.

    Question 4. Other than Carr, has an FCC chair ever threatened a 
network or local affiliate with regulatory action based on the content 
of a late-night comedian's monologue?
    Answer. Not to my knowledge.

    Question 5. Have the FCC's actions since the Nixon administration 
to revoke broadcast licenses been limited to concerns over the 
licensee's character, such as being a convicted criminal, and not based 
on the content of the licensee's speech?
    Answer. Yes
    The Communications Act of 1934 requires broadcast licensees to 
serve the ``public interest, convenience, and necessity,'' and grants 
the FCC authority to consider those interests when granting or renewing 
licenses. The FCC has long held that ``the public interest is best 
served by permitting free expression of views,'' and Section 326 of the 
Communications Act specifically prohibits the Commission from 
``censorship.''

    Question 6. Does the ``public interest'' standard legally permit 
the FCC Chair to suppress speech by revoking the licenses of 
broadcasters for airing content the Administration does not like?
    Please explain.
    Answer. No

    Question 7. Should an FCC Chair repeatedly mislead the American 
public that the FCC's longstanding public interest standard should be 
used to suppress speech? Please explain.
    Answer. I fear that repeated statements from the FCC Chair 
describing a power to suppress speech, which clearly exceeds his 
authority, has a chilling effect on public discourse and harms open, 
democratic debate in our society.

    Media Consolidation. Americans rely on local news to understand 
what's going on in their communities. According to the Pew Research 
Center, nearly three-quarters of Americans trust their local newspapers 
and broadcasters. But local news faces serious headwinds. The 
advertising-supported model of local newspapers and local broadcast has 
declined, with an increasing share of revenue going to tech platforms 
rather than news organizations.
    There has been a wave of consolidation in the media, ranging from 
broadcast affiliates to newspapers. And for many Americans, most of 
their news comes through social media algorithms, giving the owners of 
these platforms inescapable influence over what we see and read.

    Question 1. What are the effects of media consolidation on the 
diverse voices and viewpoints that we need for a vibrant democracy?
    Answer. Excessive media consolidation is likely to reduce open, 
diverse debate in our society, undermining the marketplace of ideas 
that is essential for a vibrant democracy.

    Question 2. Does the increasing consolidation of media make it more 
vulnerable to pressure from politicians?
    Answer. Politicians can always try to pressure the media, however 
the fewer the owners the easier it is to make that pressure succeed. 
The more media is diversely owned by independent companies, the more 
difficult it is for politicians to steer public debate to serve their 
self interest.

    Social Media and Antitrust. Social media platforms are increasingly 
the most important town square in our democracy. The algorithms decide 
the topics that are debated and the views that are represented. Because 
of the power of these platforms in our society, there has been a 
bipartisan recognition of the need to hold them to account. To date, 
the most prominent efforts have been through antitrust law.
    Major antitrust cases were brought against several platforms by the 
first Trump administration and the Biden administration and have been 
continued through transitions.

    Question 1. Is antitrust the right tool to bring platforms to heel?
    Answer. Antitrust is an essential tool to address market abuses by 
tech platforms, however it is not sufficient to address all the 
impediments to robust competition in digital markets.

    Question 2. What other policies should we consider to ensure these 
platforms serve individuals and support a democratic society, rather 
than undermine it?
    Answer. Congress should consider making it easier to bring 
antitrust cases against dominant digital platforms, and it should also 
create some regulatory guardrails to prevent discriminatory practices.

    Public Media and Local Journalism. Grants from CPB support nearly 
400 public radio stations across the country, which employ nearly 9,800 
people, including 3,000 local journalists, editors, and producers. With 
their signal reach, particularly in rural areas, public radio stations 
can help to slow the spread of ``news deserts,'' or areas that have no 
source of local news.
    Of the 204 ``news desert'' counties identified by the State of 
Local News Project, 67 are served by local public radio signals. 
Newsrooms have lost over 60 percent of their newsroom employees over 
the last two decades. Meanwhile, public radio has added 900 local 
newsroom employees since 2012.
    Despite this, Republicans zeroed out Federal funding for public 
broadcasting earlier this year, costing more than 400 jobs in public 
media, putting dozens of stations at risk of closure, and causing the 
Corporation for Public Broadcasting to close down.

    Question 1. How does public media enhance local journalism?
    Answer. Public media has served a critical role in local markets, 
filling in information gaps left by the disappearance of private media 
players. Without public media, and with the shuttering of numerous 
local newspapers, many communities will be deprived of the information 
flow we rely upon to fuel a robust democracy.

    Question 2. What will be the effect of Republicans defunding public 
broadcasting?
    Answer. Given the enormous loss of local information flowing 
through local newspapers, any reduction in public media threatens to 
harm the marketplace of ideas that is critical to an informed 
citizenry.
                                 ______
                                 
   Response to Written Questions Submitted by Hon. Amy Klobuchar to 
                             Gene Kimmelman
Question Topic: Antitrust and the First Amendment
    Competitive markets can help ensure that no one entity controls 
what we see or hear. But when markets become consolidated, access to 
diverse viewpoints is put at risk. In your testimony, you said that 
antitrust is a necessary but often insufficient tool to sustain diverse 
local media.

   How have Big Tech platforms used their position as content 
        gatekeepers to siphon away resources from local media, 
        including by misappropriating content?
    Answer. As more and more people rely upon the Internet as a gateway 
for their information needs, the dominant tech platforms (e.g., Google, 
Apple, Meta) have enormous power over how news and media content are 
disseminated. Control of these gateways to the public is synonymous 
with control over the advertising and related revenue necessary to 
produce content and report on local, societal and even global events. 
It is critical to prevent tech platforms from expropriating revenue 
necessary to fund high quality content.
Question Topic: AI and Local Media
    A free press is a crucial part of our democracy, but local news is 
facing an existential crisis. Since 2005, the U.S. has lost about 3,300 
local newspapers, roughly one-third of newspapers nationally. The pace 
of these newspaper closures is accelerating at a time when tech 
companies are using local news content to train AI models without 
compensating journalists and papers for their critical contributions.

   What role should companies that profit from AI models that 
        use news content play in ensuring journalists and newspapers 
        are fairly compensated?
    Answer. Companies that build AI models with content created by 
others should pay license fees or royalties to content creators. We 
have done this for music and broadcasting in the past, and now is the 
time to do something similar for AI models.
Question Topic: Political Violence
    Our country has endured a troubling wave of political violence that 
threatens public safety and our democracy. Elected officials from both 
parties must bring down the temperature of our political discourse, 
especially online, where a lot of this hate is spread.

   How would transparency from platforms regarding their 
        ranking algorithms help address the algorithmic amplification 
        of violent political rhetoric?
    Answer. Transparency should put pressure on the tech platforms to 
address the dangers they create or contribute to by amplifying violent 
content. Transparency should enable the public to reject engaging with 
platforms that promote violence, creating financial benefits for 
platforms that seek to limit algorithmic amplification of violence.

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