What is unique is that disinformation is being spread through means that by
themselves erode trust in the outcomes of democratic processes and hinder effective
discourse around policy. Part of this is the perceived – and potentially actual –
advantage that tools such as bots, advertisement microtargeting, the ﬁnancial
resources of a foreign government, and other tactics confer to actors spreading a

58 Ashcroft v. American Civil Liberties Union, 542 U.S. 656, 660.
59 United States v. Alvarez, 567 U.S. 709.
62 id., at 727.
63 id., at 724 (citing Turner Broadcasting System, Inc. v. FCC, 512 U.S. 622, 642).
64 id., at 718.
65 See, e.g., Meacham (2013), which details political lies during the 1800 US presidential campaign.

61 id., at 719, 723.

60 See id., at 715.

https://doi.org/10.1017/9781108890960 Published online by Cambridge University Press

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