In ACLU of Nevada v. City of Las Vegas, 466 F.3d 784 (9th Cir.2006), the Court considered whether an ordinance banning solicitation at certain Las Vegas locations was content-neutral. The ordinance prohibited any solicitation, defined as "`to ask, beg, solicit or plead, whether orally, or in a written or printed manner, for the purpose of obtaining money, charity, business or patronage, or gifts or items of value for oneself or another person or organization.'" ACLU, 466 F.3d at 788 (quoting Las Vegas Municipal Code 10.44.010(A)). The ordinance was interpreted to prohibit the distribution of handbills or leaflets that solicit money or donations, regardless of whether they involved a request for immediate or future donations. Id. The three-judge panel concluded that the ordinance was not content-neutral because, "in order to enforce the regulation, an official `must necessarily examine the content of the message that is conveyed.'" Id. at 794. In other words, because law enforcement would have to read the content of the message conveyed to determine whether it fell within the ban, the ordinance was content-based. See id. at 794 & 796. The three-judge panel distinguished ACORN and prior Supreme Court cases, which had previously held solicitation regulations to be content-neutral, by characterizing those cases as involving regulations of the "act of solicitation" and not "words of solicitation." Id. In essence, the panel held that solicitation regulations can be content-neutral only if they regulate "an element of conduct interwoven with otherwise expressive solicitation." Id. at 795 (quoting Lee, 505 U.S. at 705, 112 S.Ct. 2701 (Kennedy, J., concurring)). But, if the regulation restricts only the speech associated with the solicitation, it is content-based and therefore violates the First Amendment unless it survives strict scrutiny. See id.