 U.S. Court of Appeals judge Alex Kozinski criticized the 1942 "Valentine v. Chrestensen" ruling, stating that "the Supreme Court plucked the commercial speech doctrine out of thin air".The European Court of Human Rights has held that commercial speech is protected under Article 10 of the European Convention on Human Rights (ECHR) on several occasions since the 1980s, but lacks a counterpart to the commercial speech doctrine that exists under U.S. law.In Germany, the courts adopted a strict approach to advertising and commercial speech due to its emphasis on ensuring competition.