Keane J 32. Donation as communication 97 The plaintiffs submitted that making a political donation constitutes a political communication on the basis that "actions as well as words can communicate ideas." 85 98 Decisions of the United States Supreme Court were cited by the plaintiffs to support the propositions that, from the perspective of the donor, a political donation "serves as a general expression of support for the candidate and his views" 86, and from the point of view of the donee, the acceptance of a donation is an expression of the willingness of a candidate to be associated with, and to accept the support of, the donor. Thus, in Colorado Republican Federal Campaign Committee v Federal Election Commission 87, Thomas J observed: "Whether an individual donates money to a candidate or group who will use it to promote the candidate or whether the individual spends the money to promote the candidate himself, the individual seeks to engage in political expression and to associate with like-minded persons." 99 In relation to sub-ss (1), (3) and (4) of s 96D, the plaintiffs relied upon Citizens United v Federal Election Commission 88 to argue that political communications by corporations and industrial organisations should not be treated differently from those of enrolled voters simply because such organisations are not natural persons entitled to vote. 100 This ground of the plaintiffs' challenge to the validity of s 96D should be rejected for reasons which reflect a substantial difference in the constitutional arrangements of the Commonwealth and the United States. 101 The First Amendment to the United States Constitution provides that "Congress shall make no law … abridging the freedom of speech". The First Amendment guarantees a right of free speech 89. It is a personal right to express one's views on any topic, whether that be to participate in the market place of 85 Levy v Victoria (1997) 189 CLR 579 at 594; [1997] HCA 31. 86 Buckley v Valeo 424 US 1 at 21 (1976). 87 518 US 604 at 638 (1996). 88 175 L Ed 2d 753 (2010). 89 New York Times Co v Sullivan 376 US 254 (1964); Citizens United v Federal Election Commission 175 L Ed 2d 753 at 782, 815, 867 (2010).