Kay was criticized for citing a Kevin Alfred Strom quotation which is often to Voltaire—"To learn who rules over you, simply find out who you are not allowed to criticize." The original quotation is: "To determine the true rulers of any society, all you must do is ask yourself this question: Who is it that I am not permitted to criticize? We all know who it is that we are not permitted to criticize. We all know who it is that it is a sin to criticize. … nti-semitism is the ultimate sin in America." It was written by Strom, an American white nationalist and neo-Nazi, in his 1993 publication. In a "Canadaland" article, Jonathan Goldsbie wrote that Kay had tweeted the phrase in April 2017. In her blog post, "Bill C-16, or The Transgender Identity Bill, is an act of "Velvet Totalitarianism", Kay compared the October 2017 Transgender Rights Bill to compelled speech in Voltaire's 18th century when it "was dangerous to criticize the Catholic Church and its dogmas. In our era, it is dangerous to criticize the Church of Gender Identity and its dogmas." During the July 18, 2018 panel discussion on the Bill C-16 Controversy, hosted by the Rights and Freedoms Institute, Kay used the phrase again to describe her "quarrel" with "compelled speech" and "compelled expression of belief" in regards to the use of genderless pronouns. Kay said it was ironic that she used Strom's words, but felt they the words of the quotation made sense, even if they are those of a Holocaust denier.