In Shapero v. Kentucky Bar Ass'n, 486 U.S. 466 (1988), the Court invalidated a regulation that prohibited lawyers from soliciting legal business for pecuniary gain by sending truthful and nondeceptive letters to potential clients who the lawyer knew faced a particular legal problem. In that case, the Kentucky Supreme Court disapproved of Shapero's letter simply because it was directed to those who the attorney knew would need his services, even though a mailing to the public at large would necessarily include persons known to need Shapero's services. See id. at 473. The Court concluded: "The First Amendment does not permit a ban on certain speech merely because it is more efficient; the State may not constitutionally ban a particular letter on the theory that to mail it only to those whom it would most interest is somehow inherently objectionable." Id. at 473-74. The Court reasoned that the mere opportunity "for isolated abuses or mistakes does not justify a total ban on that mode of protected commercial speech." Id. at 476.