In Riley v. National Federation of the Blind, 487 U.S. 781, 788-89, 108 S. Ct. 2667, 101 L. Ed. 2d 669 (1988), the Court considered a North Carolina statute that prohibited unreasonable fees as described in a three-tier schedule: A fee up to 20% of the gross receipts collected is deemed reasonable. If the fee retained is between 20% and 35%, the Act deems it unreasonable upon a showing that the solicitation at issue did not involve the "dissemination of information, discussion, or advocacy relating to public issues as directed by the charitable organization which is to benefit from the solicitation." Finally, a fee exceeding 35% is presumed unreasonable, but the fundraiser may rebut the presumption by showing that the amount of the fee was necessary either: (1) because the solicitation involved the dissemination of information or advocacy on public issues directed by the charity, or; (2) because otherwise the charity's ability to raise money or communicate would be significantly diminished. Riley, 487 U.S. at 784-86. Also challenged in Riley was a disclosure requirement that a professional fundraiser disclose "the average percentage of gross receipts actually turned over to charities by the fundraiser for all charitable solicitations conducted in North Carolina within the previous 12 months." Id. at 786. Regarding this provision, the Court stated, "mandating speech that a speaker would not otherwise make necessarily alters the content of the speech. We therefore consider the Act as a content-based regulation of speech." Id. at 795. North Carolina stated that its substantial interest supporting this provision was "the importance of informing donors how the money they contribute is spent in order to dispel the alleged misperception that the money they give to professional fundraisers goes in greater-than-actual proportion to benefit charity." Id. at 798. The Court noted that this interest was not substantial enough to support the infringement on protected speech. Id. The Court also noted that other, unchallenged provisions, such as the requirement that professional fundraisers "disclose their professional status to potential donors" would put the public on notice that not all of the money they donate would go to the charitable organization, and that potential donors could then ask what percentage would go to the charity. Id. at 799.