In Zauderer v. Office of Disciplinary Counsel, 471 U.S. 626 (1985), the Court reversed in part an Ohio decision disciplining an attorney for recommending his services in a newspaper advertisement that included legal advice. See id. at 626. Specifically, the attorney had advertised his willingness to represent women who had suffered injury from the use of the Dalkon Shield intrauterine contraceptive device. See id. at 629-30. The Zauderer Court commented that a restriction which sought to prevent litigation by prohibiting information to the public relating to potentially legitimate claims would be unconstitutional. See 471 U.S. at 642-44.