PANews reported on April 21 that, according to Cointelegraph, Coin Center released a report stating that software code constitutes "functional" speech and should be protected by the First Amendment to the U.S. Constitution. The report's authors, Coin Center Executive Director Peter Van Valkenburgh and Research Director Lizandro Pieper, argue that writing and releasing cryptographic software code is no different from writing a book or publishing a cookbook. The First Amendment provides strict constitutional protection for developers who only release and maintain software. Only when developers control user assets, execute transactions on behalf of users, or make decisions on behalf of users does it fall under the category of regulated behavior. The report cites the 1985 case of Lowe v. SEC, where the Supreme Court ruled that publishers who do not hold assets on behalf of clients or act on behalf of clients are protected by free speech and are not considered to be engaged in a regulated profession.