The only speech I'm talking about, the only speech which was the subject of Citizens United, is core political speech.
In that context, in the traditional US context, there's no "fraud", AKA criminal libel. Although I don't agree with the extremes of New York Times Co. v. Sullivan, which removed useful feedback in the system in the civil law arena, current case law makes protection of core political speech all but "absolute".
"There was a rumor going around the circle of journalists, and while I was the one who started the rumor, its existence meant I could report it as a fact."
In that context, in the traditional US context, there's no "fraud", AKA criminal libel. Although I don't agree with the extremes of New York Times Co. v. Sullivan, which removed useful feedback in the system in the civil law arena, current case law makes protection of core political speech all but "absolute".