A Beginner’s Guide to Freedom of Press and Legal Protections

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Table of Contents

Freedom of press is a fundamental pillar of democratic societies, serving as a critical check on government power and ensuring that citizens have access to the information they need to make informed decisions. This essential right protects journalists, media organizations, and individuals from government censorship and interference, allowing them to investigate, report, and publish news and opinions without fear of retaliation. Understanding the legal framework that protects press freedom, the challenges it faces, and its vital role in society is crucial for anyone interested in journalism, civil liberties, or the health of democratic institutions.

Understanding Freedom of Press: Definition and Scope

Freedom of the press in the United States is legally protected by the First Amendment to the United States Constitution. The First Amendment states: “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.” It was adopted on December 15, 1791, as one of the ten amendments that constitute the Bill of Rights.

Freedom of the press is the protected right to freely publish communications and expressions of opinions through various forms of media. This freedom protects the right to gather information and report it to others. The scope of press freedom extends far beyond traditional newspapers and print media. While at the time of ratification in 1791, the free press clause addressed newspapers, it now applies to all forms of newsgathering and reporting, independent of medium. This includes television, radio, online journalism, blogs, social media, and any other platform used to disseminate information and ideas to the public.

Freedom of the press limits the government’s control or censorship over the media, except in the most severe national security risk potential. At its core, this freedom means that government authorities cannot dictate what journalists publish, cannot punish reporters for covering controversial topics, and cannot suppress information simply because it is critical of those in power. This protection is essential for maintaining transparency, accountability, and the free flow of information that democracies depend upon.

In Lovell v. City of Griffin (1938), Chief Justice Charles Evans Hughes defined the press as “every sort of publication which affords a vehicle of information and opinion.” This broad definition ensures that press protections evolve with technology and changing media landscapes, extending constitutional safeguards to new forms of communication as they emerge.

The Historical Foundation of Press Freedom

Colonial Origins and Early American Press

The American commitment to press freedom emerged from the colonists’ experience under British rule, where criticism of the monarchy could result in severe punishment. Under British rule, criticism of the king could land you in jail. The government tightly controlled the press, and dissent was criminalized. This oppressive environment made the founders acutely aware of the dangers posed by government control over information and expression.

It is notable that though 18th century newspapers were often highly biased and often irresponsible in their claims, the nation’s leaders saw protection of the press as a valuable check on potential corruption and official misdeeds. The founders understood that even imperfect journalism served a crucial democratic function by providing a forum for debate and holding powerful figures accountable.

Early Challenges: The Alien and Sedition Acts

The commitment to press freedom was tested early in American history. In 1798, eleven years after adoption of the Constitution and seven years after ratification of the First Amendment, the governing Federalist Party attempted to stifle criticism with the Alien and Sedition Acts. According to the Sedition Act, making “false, scandalous and malicious” statements about Congress or the president (but not the vice-president) was a crime; Thomas Jefferson, a Democratic-Republican, was vice-president when the act was passed.

These restrictions on the press were very unpopular, leading to the party’s reduction to minority status after 1801, and eventual dissolution in 1824. Jefferson, who vehemently opposed the acts, was elected president in 1800 and pardoned most of those convicted under them. This episode demonstrated the American public’s strong commitment to press freedom and established an important precedent against government attempts to criminalize criticism.

Evolution Through Supreme Court Decisions

The First Amendment that we know today largely emerged from pivotal U.S. Supreme Court decisions in the 20th century. Starting in the 1920s, the Supreme Court began to read the First Amendment more broadly, and this trend accelerated in the 1960s. Today, the legal protection offered by the First Amendment is stronger than ever before in our history.

The Court affirmed the rights to free speech and a free press as fundamental constitutional rights. It held that the due process clause of the Fourteenth Amendment protects these rights from restrictions by state and local government. This is known as the doctrine of incorporation. This development meant that press freedom protections applied not just to federal actions but to state and local governments as well, significantly expanding the scope of constitutional protection.

Protection Against Prior Restraint

One of the most fundamental protections for press freedom is the prohibition against prior restraint—government censorship before publication. The 1931 U.S. Supreme Court decision Near v. Minnesota recognized freedom of the press by roundly rejecting prior restraints on publication, a principle that applied to free speech generally in subsequent jurisprudence. The court ruled that a Minnesota law targeting publishers of malicious or scandalous newspapers violated the First Amendment (as applied through the Fourteenth Amendment).

The Court explained that the very meaning of a free press is the absence of prior restraints on publications. Because the law constituted a prior restraint, the Court held it was an unconstitutional infringement on the First Amendment right to a free press. This marked the beginning of the prior restraint doctrine. While there are narrow exceptions for extreme circumstances such as national security threats, prior restraints are generally considered unconstitutional.

The Pentagon Papers Case

One of the most iconic press freedom cases in U.S. history came during the Vietnam War. In the 1970s, The New York Times published the Pentagon Papers — classified documents revealing that the U.S. government had misled the public about the war. President Nixon tried to block publication, arguing it threatened national security. The Times argued the public had a right to know. The Supreme Court ruled 6–3 in favor of the Times, affirming that even highly sensitive material could be published if it served the public interest.

The Court determined that the administration failed to establish that the national security concerns raised by publishing the leaked material outweighed the papers’ First Amendment rights. This case is widely regarded as a free press victory against government censorship. The Pentagon Papers case established that even when the government claims national security concerns, it bears a heavy burden to justify prior restraint on publication.

Defamation Standards and Public Figures

Press freedom includes important protections against defamation lawsuits that could otherwise be used to silence critical reporting. In New York Times Co. v. Sullivan (1964), the court held the press is largely free from any adverse act or court action if it attempts truthfully to report news of public concern; and when the news involves a public official, even erroneous reportage has a high degree of protection.

The Supreme Court held that defamation or libel was not protected by the First Amendment, and that when a statement concerns a public official, the official must show that the statement was made with “actual malice.” The Court defined such malice as knowledge that the statement was false or demonstrating a reckless disregard for its falsity. This “actual malice” standard makes it significantly more difficult for public officials and public figures to win defamation cases, protecting journalists from being silenced through litigation even when they make honest mistakes in their reporting.

Shield Laws and Source Protection

Protecting confidential sources is crucial for investigative journalism, as many important stories depend on whistleblowers and insiders who will only speak on condition of anonymity. Many states have shield laws that let journalists protect their sources. But there’s no federal shield law, so protections vary wildly. The press often acts as government watchdogs; therefore, many states have enacted reporter shield laws to protect the confidentiality of sources of information.

However, source protection remains a contested area of press law. In Branzburg v. Hayes (1972), the Supreme Court ruled that journalists don’t have a constitutional right to withhold sources when subpoenaed. Since then, it’s been a legal gray area that’s still evolving — and often dangerous for investigative journalism. The absence of a federal shield law and the varying state protections create uncertainty for journalists working on sensitive stories that rely on confidential sources.

Access to Information and Government Proceedings

While the press has important protections for what it publishes, its rights to access information are more limited. Several Supreme Court holdings firmly point to the conclusion that the Free Press Clause does not confer on the press the power to compel government to furnish information or otherwise give the press access to information that the public generally does not have. Nor, in many respects, is the press entitled to treatment different in kind from the treatment to which any other member of the public may be subjected.

However, the press does have important access rights in certain contexts. In Richmond Newspapers, Inc. v. Virginia (1980), the court affirmed a First Amendment right for both the public and the press to attend criminal trials. This right to access court proceedings helps ensure transparency in the judicial system and allows the press to serve its watchdog function.

The Democratic Function of a Free Press

Informing the Public and Ensuring Accountability

The First Amendment rights to free speech and a free press are essential to American democracy. Without these protected freedoms, our free and unfettered discourse on government affairs and other matters of public concern would be compromised. A free press is a cornerstone of democracy. It informs the public, keeps leaders honest, exposes injustice, and ensures transparency at all levels — from City Hall to Capitol Hill.

The Supreme Court laid out the purpose of the free press clause: “there is practically universal agreement that a major purpose of [the First Amendment] was to protect the free discussion of governmental affairs. The press serves and was designed to serve as a powerful antidote to any abuses of power by governmental officials, and as a constitutionally chosen means for keeping officials elected by the people responsible to all the people whom they were selected to serve.”

A press that is not controlled by the government sits in the nation’s courtrooms as a guardian and watchdog over the people’s rights to an independent judiciary, a fair trial and equal protection under the law. This watchdog function extends across all branches and levels of government, helping to expose corruption, inefficiency, and abuses of power that might otherwise remain hidden from public view.

Protecting the Public’s Right to Receive Information

Press freedom is not just about protecting journalists—it’s fundamentally about protecting the public’s right to information. Freedom of the press functions as a limitation on government regulation. This means the right doesn’t just protect press entities. It also protects the public’s right to receive information, particularly about government affairs and other matters of public concern.

The Constitution protects, according to the Supreme Court in Stanley v. Georgia (1969), the right to receive information and ideas, regardless of their social worth, and to be generally free from governmental intrusions into one’s privacy and control of one’s thoughts. This reciprocal relationship between the press’s right to publish and the public’s right to receive information underscores that press freedom serves broader democratic values beyond the interests of media organizations themselves.

Promoting Transparency and Good Governance

Freedom of the press remains a precious and vital liberty, ensuring that people can criticize public officials, expose government corruption, and distribute material on virtually any subject imaginable, free from most prior restraints and other forms of censorship. By shining light on government operations, the press helps deter misconduct and encourages officials to act in the public interest.

The Supreme Court stated in Thornhill v. Alabama (1940) that the freedom of speech and of the press guaranteed by the United States Constitution embraces at the least the liberty to discuss publicly and truthfully all matters of public concern, without previous restraint or fear of subsequent punishment. This protection for discussing matters of public concern creates an environment where government actions can be scrutinized and debated, leading to better-informed policy decisions and more responsive governance.

Who Is Protected by Press Freedom?

Beyond Traditional Media Organizations

Press freedom protections extend far beyond traditional newspapers and broadcast media. Press is not limited to professional publications or journalists but applies to any type of publisher. Freedom of the press protects newspapers, television shows, social media, or any other forms of news sources to freely investigate and report information to the public.

Although it had been uncertain whether people who blog or use other social media are journalists entitled to protection by media shield laws, they are protected by the Free Speech and Free Press Clauses (neither of which differentiates between media businesses and nonprofessional speakers). This means that citizen journalists, bloggers, podcasters, and social media users all enjoy First Amendment protections when they gather and disseminate news and information.

The Institutional Press Debate

It has been much debated, for example, whether the “institutional press” is entitled to greater freedom from governmental regulations or restrictions than are non-press individuals, groups, or associations. Justice Stewart has argued: “That the First Amendment speaks separately of freedom of speech and freedom of the press is no constitutional accident, but an acknowledgment of the critical role played by the press in American society.”

However, the Supreme Court has generally declined to grant special privileges to institutional media. The Supreme Court has refused to grant increased First Amendment protection to institutional media over other speakers; In a case involving campaign finance laws, the court rejected the “suggestion that communication by corporate members of the institutional press is entitled to greater constitutional protection than the same communication by” non-institutional-press businesses. This approach ensures that press freedom protections are available to all who engage in newsgathering and dissemination, not just established media organizations.

Corporate and Organizational Speech

The issue, the Court wrote in Bellotti, was not what constitutional rights corporations have but whether the speech that is being restricted is protected by the First Amendment because of its societal significance. The First Amendment protects and fosters individual self-expression as a worthy goal, it also and as importantly affords the public access to discussion, debate, and the dissemination of information and ideas. This focus on the value of speech to society, rather than the identity of the speaker, helps ensure robust protection for diverse voices and perspectives.

Limitations and Boundaries of Press Freedom

Constitutional Limits on Press Freedom

The constitutional rights to free speech and a free press are not without limits. They need to be weighed against the interests of society and government. Consequently, the Supreme Court has set forth various permissible limitations on speech and the press. Likewise, it has developed frameworks and legal standards for analyzing whether government action is consistent with the First Amendment.

Generally speaking, it means that the government may not jail, fine, or impose civil liability on people or organizations based on what they say or write, except in exceptional circumstances. These exceptional circumstances include categories of speech that fall outside First Amendment protection, such as true threats, incitement to imminent lawless action, and certain forms of obscenity.

National Security Considerations

While the Pentagon Papers case established strong protections against prior restraint even for classified information, national security remains one area where press freedom may face legitimate restrictions. The Near Court also recognized “exceptional cases” in which prior restraint was permissible, including: … Generally speaking, however, they are deemed unconstitutional. The government must meet an extremely high burden to justify prior restraint on national security grounds, demonstrating that publication would cause direct, immediate, and irreparable harm.

Privacy Rights and Newsgathering Methods

Freedom of the press not only protects free publication, but also news-gathering. In general, the press has the same rights as the public and cannot invade others privacy protections. Journalists must respect laws against trespass, wiretapping, and other illegal methods of obtaining information. While the press can publish legally obtained information on matters of public concern, the methods used to gather that information are subject to generally applicable laws.

Generally Applicable Laws

The Court has ruled that [g]enerally applicable laws do not offend the First Amendment simply because their enforcement against the press has incidental effects. This means that laws that apply to everyone—such as tax laws, labor laws, or antitrust regulations—can be enforced against media organizations even if compliance imposes some burden on their operations. However, the Court has recognized that laws targeting the press, or treating different subsets of media outlets differently, may sometimes violate the First Amendment. For example, a tax focused exclusively on newspapers violated the freedom of the press.

Contemporary Challenges to Press Freedom

Threats and Violence Against Journalists

Despite constitutional protections, journalists around the world and even in democratic countries face physical threats, harassment, and violence. These threats can come from government actors, criminal organizations, or individuals angered by critical coverage. Such intimidation has a chilling effect on press freedom, as journalists may self-censor or avoid covering dangerous topics to protect their safety. The murder or imprisonment of journalists represents one of the most severe threats to press freedom, silencing critical voices and deterring others from pursuing investigative work.

Government Pressure and Retaliation

Governments may attempt to suppress critical coverage through various means short of direct censorship. These can include denying press credentials, limiting access to information and officials, using regulatory agencies to harass media organizations, or threatening legal action. If a journalist uncovers corruption and the government responds by revoking credentials, issuing threats, or cutting off access? That’s a red flag — and likely a First Amendment violation. Such retaliatory actions can effectively punish critical reporting even without formal censorship.

Economic Pressures on News Organizations

The business model for journalism has been severely disrupted by technological change and shifting advertising markets. Many news organizations have closed or dramatically reduced their staffing, particularly at the local level. This economic pressure threatens press freedom not through government action but through market forces that make it increasingly difficult to sustain quality journalism. When news organizations struggle financially, they may have fewer resources for investigative reporting, legal defense, or coverage of important but less profitable topics.

While the actual malice standard provides important protections for reporting on public figures, defending against defamation lawsuits can be extremely expensive. Even when media organizations ultimately prevail, the cost of litigation can be financially devastating, particularly for smaller outlets. Strategic lawsuits against public participation (SLAPP suits) may be filed not with the expectation of winning but to burden critics with legal costs and deter future critical coverage. Many states have enacted anti-SLAPP laws to address this problem, but the threat of expensive litigation remains a significant challenge to press freedom.

Digital Age Challenges

The digital revolution has created new challenges for press freedom. Online harassment and doxxing of journalists can create serious safety concerns. Governments may attempt to compel technology companies to remove content or provide information about sources. The global nature of the internet means that journalists may face legal threats from multiple jurisdictions with different standards for press freedom. Additionally, the spread of misinformation and disinformation has led to calls for content moderation that could potentially impact legitimate journalism.

Surveillance and Source Protection

Government surveillance capabilities have expanded dramatically in the digital age, creating new threats to source confidentiality. When communications can be monitored and metadata analyzed, protecting confidential sources becomes more challenging. Journalists may need to use encryption and other security measures to protect their sources, but these tools are not foolproof. The tension between national security surveillance programs and the need to protect journalistic sources remains an ongoing challenge.

Concerns About Press Restrictions

In a Pew Research survey of 11,889 U.S. journalists conducted from February 16 to March 17, 2022, 57% stated that they were “extremely” or “very” concerned about the prospect of press restrictions being imposed in the United States. This high level of concern among journalists themselves reflects the perception that press freedom faces significant threats even in countries with strong constitutional protections.

International Perspectives on Press Freedom

Global Press Freedom Rankings

Freedom House, a U.S.-based watchdog organization, ranked the United States 30th out of 197 countries in press freedom in 2014. Its report praised the constitutional protections given American journalists and criticized authorities for placing undue limits on investigative reporting in the name of national security. Such rankings help provide comparative context for understanding press freedom globally and identifying areas where even democratic countries can improve.

Different countries approach press freedom through different legal frameworks. Some countries have constitutional protections similar to the U.S. First Amendment, while others rely on statutory protections or international human rights treaties. The European Convention on Human Rights, for example, protects freedom of expression but allows for broader restrictions than U.S. law in areas such as hate speech and privacy. Understanding these different approaches helps illuminate the choices involved in balancing press freedom against other societal interests.

Authoritarian Restrictions

In many countries, press freedom is severely restricted through censorship, licensing requirements, state control of media, and criminal penalties for critical reporting. Journalists in authoritarian countries may face imprisonment, torture, or death for their work. These extreme restrictions demonstrate the importance of strong legal protections for press freedom and the constant vigilance required to maintain them even in democratic societies.

The Role of Technology in Press Freedom

Digital Publishing and Distribution

The internet has dramatically lowered the barriers to entry for publishing and distributing news and information. Anyone with an internet connection can now reach a global audience, democratizing access to the public sphere. This technological shift has enabled new forms of journalism, from independent blogs to collaborative investigative projects. However, it has also created challenges around quality control, verification, and the economic sustainability of professional journalism.

Social Media Platforms

Social media platforms have become crucial infrastructure for news distribution, but they are private companies not bound by the First Amendment. Their content moderation decisions can significantly impact what information reaches the public, raising questions about the appropriate balance between platform autonomy and the public interest in access to information. The relationship between traditional press freedom principles and platform governance remains an evolving area of law and policy.

Encryption and Security Tools

Encryption and other security technologies have become essential tools for journalists working on sensitive stories. These technologies help protect confidential sources, secure communications, and safeguard unpublished materials from unauthorized access. However, governments sometimes seek to restrict or weaken encryption, creating tension between security needs and press freedom. The ability of journalists to use strong encryption may be crucial for maintaining source confidentiality in an era of pervasive surveillance.

Protecting and Strengthening Press Freedom

Strengthening press freedom requires ongoing legal reforms and protections. This includes enacting federal shield laws to protect confidential sources, strengthening anti-SLAPP statutes to deter frivolous lawsuits, and ensuring that freedom of information laws provide meaningful access to government records. Legal protections must evolve to address new challenges posed by technology and changing media landscapes.

Public Support and Media Literacy

Press freedom ultimately depends on public support and understanding. Media literacy education helps citizens critically evaluate news sources, understand the role of journalism in democracy, and recognize the importance of press freedom. When the public values and supports quality journalism, it creates both market incentives for good reporting and political pressure to maintain strong legal protections.

Professional Standards and Ethics

The press itself has a responsibility to maintain high professional and ethical standards. Accurate, fair, and responsible journalism builds public trust and strengthens the case for robust press freedom protections. Professional organizations, journalism schools, and news organizations all play important roles in promoting ethical practices and accountability within the profession.

International Cooperation

Press freedom is increasingly a global issue requiring international cooperation. Journalists working across borders need protections in multiple jurisdictions. International organizations and treaties can help establish norms and provide support for journalists facing threats. Cooperation among democratic countries can help counter authoritarian efforts to restrict press freedom and support independent journalism in repressive environments.

The Future of Press Freedom

Emerging Technologies

Artificial intelligence, virtual reality, and other emerging technologies will create new opportunities and challenges for journalism and press freedom. AI could assist with research and fact-checking but also enable sophisticated disinformation. New platforms and formats will require adapting press freedom principles to novel contexts. The legal framework protecting press freedom must remain flexible enough to address technologies that don’t yet exist.

Economic Sustainability

Finding sustainable business models for quality journalism remains one of the most pressing challenges for press freedom. Experiments with nonprofit journalism, membership models, and public funding all offer potential paths forward. The economic viability of news organizations directly impacts their ability to serve the public interest and exercise press freedom effectively.

Balancing Competing Values

Press freedom will continue to require balancing against other important values such as privacy, national security, and protection from harmful speech. These tensions are inherent in any system of rights and freedoms. The challenge is to strike appropriate balances that protect press freedom while addressing legitimate concerns, avoiding both excessive restrictions and absolute positions that ignore real harms.

Global Democratic Challenges

The health of press freedom is closely tied to the broader health of democratic institutions. As democracies face challenges from populism, polarization, and authoritarianism, press freedom often comes under pressure. Defending press freedom requires defending democracy itself and the norms and institutions that support it. The future of press freedom depends on continued commitment to democratic values and vigilance against threats from all sources.

Practical Implications for Different Stakeholders

For Journalists and Media Organizations

Understanding press freedom protections is essential for journalists and media organizations to effectively exercise their rights. This includes knowing when prior restraint is prohibited, understanding defamation standards, recognizing the limits of source protection, and being aware of both rights and responsibilities when gathering news. Journalists should also understand the practical security measures needed to protect sources and sensitive information in the digital age.

For Citizens and News Consumers

Citizens benefit from press freedom through access to information needed for democratic participation. Understanding press freedom helps citizens recognize when it is under threat and why it matters. Supporting quality journalism through subscriptions, donations, or other means helps sustain the economic foundation for press freedom. Critically evaluating news sources and understanding the difference between journalism and other forms of content helps maintain the value of professional reporting.

For Government Officials

Government officials have a responsibility to respect press freedom even when coverage is critical or inconvenient. This means avoiding retaliation against critical reporters, providing meaningful access to information, and recognizing the press’s watchdog role as essential to democratic accountability. Officials should understand that press freedom serves the public interest even when it creates short-term political challenges.

Lawyers play crucial roles in defending press freedom through litigation, advising media organizations, and shaping the development of First Amendment law. Understanding the nuances of press freedom doctrine helps lawyers effectively represent clients and contribute to the evolution of legal protections. Pro bono legal support for journalists and news organizations facing legal threats is particularly important for maintaining press freedom.

Key Takeaways and Essential Principles

Freedom of press stands as one of the foundational elements of democratic society, protected by robust constitutional and legal frameworks in many countries. The First Amendment’s protection of press freedom serves not just the interests of journalists and media organizations but the broader public interest in access to information and government accountability.

Several core principles emerge from the legal framework protecting press freedom:

  • Prior restraint on publication is almost always unconstitutional, with only narrow exceptions for extreme circumstances
  • Public officials and figures face a high burden in defamation cases, requiring proof of actual malice
  • Press freedom protections extend to all forms of media and publishers, not just traditional news organizations
  • The press generally has the same access rights as the public, without special privileges to compel disclosure of information
  • Press freedom must be balanced against other important interests, but restrictions must be narrowly tailored and justified
  • Source protection varies by jurisdiction, with state shield laws providing varying levels of protection

Despite strong legal protections, press freedom faces ongoing challenges from threats against journalists, government pressure, economic difficulties, expensive litigation, and technological changes. Maintaining robust press freedom requires constant vigilance, public support, legal reforms, and commitment to professional standards.

The democratic function of a free press cannot be overstated. By informing the public, holding power accountable, exposing corruption, and facilitating debate on matters of public concern, the press serves as an essential check on government power and a crucial institution for democratic governance. When press freedom is restricted, democracy itself is weakened.

Understanding press freedom and its legal protections is important for everyone in a democratic society—not just journalists and media professionals. Citizens who understand the role and importance of press freedom are better equipped to support it, recognize threats to it, and exercise their own rights to receive information and participate in democratic discourse.

As technology evolves and new challenges emerge, the principles underlying press freedom remain constant: government should not control what information reaches the public, journalists should be free to investigate and report without fear of retaliation, and citizens should have access to the information they need to govern themselves. These principles, enshrined in law and supported by public commitment, form the foundation for press freedom in democratic societies.

For those interested in learning more about press freedom and related topics, valuable resources include the Reporters Committee for Freedom of the Press, which provides legal resources and advocacy for journalists, the Freedom House annual press freedom reports, the Society of Professional Journalists for ethical guidelines and professional development, and the American Civil Liberties Union for broader civil liberties advocacy including press freedom issues. Academic institutions and journalism schools also offer extensive resources for understanding the legal, ethical, and practical dimensions of press freedom.

The ongoing vitality of press freedom depends on the commitment of multiple stakeholders: journalists maintaining high professional standards, legal professionals defending press rights, government officials respecting the press’s watchdog role, and citizens supporting and valuing quality journalism. Together, these efforts help ensure that press freedom continues to serve its essential democratic function in an evolving media landscape.