The correct answer is advertising.
In this case, the Virginia government made a state law outlawing any publication or communication that encouraged or prompted a person to receive an abortion. Bigelow created an advertisement simply telling women what hospitals had these services and what other services they offered to patients. In the end, the Supreme Court ruled in favor of Bigelow, as his advertisement was more than about abortions. Rather, it was about women's health services and where they could be receive help.
