Several theories of freedom of speech divide speech into the categories of "high value", "low value", and "no value". For example, Cass Sunstein has recently argued for increased governmental authority to ban pornography on the ground that, in addition to being speech that produces harms that government should seek to prevent, it is "low value" speech. The United States Supreme Court has deemed pornography to be "no value" speech, thus subject to a complete ban; and it has deemed adult books and movies and commercial speech to be "low value" speech, thus subject to regulation beyond that to which "high value" speech is subject. Dividing the realm of speech into "high value", "low value", and "no value" is quite problematic, however, and for a reason that is very seldom addressed. The statement, "Subjugate women!" appearing on a political pamphlet, may convey exactly the same meaning to its audience as a pornographic picture of a woman in bondage.