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In the late '70s and early '80s, several small bulletin board communities incorporated chat and IM into their networks.

The primary purpose of an online chat room is to communicate information with other people through text in real time. While it would appear that such protections would extend to conduct in online chat rooms, case law has determined that certain narrowly defined categories of speech or conduct do not receive constitutional protection anywhere. 2329 (1997) when it struck down portions of the Communications Decency Act (CDA) that prohibited “indecent” online publications. One type of true threat is intimidation, where the speaker directs a threat toward a person or group of people “with the intent of placing the victim in fear of bodily harm or death.” Id.

These include: (1) threats, (2) advocating imminent lawless action, (3) inciting imminent violence (“fighting words”), (4) obscenity, (5) child pornography, (6) libel, and (7) copyright or trademark infringements. Supreme Court extended the protection of the First Amendment to the Internet in Reno v. The Supreme Court has ruled that a “true threat” is not protected by the First Amendment.

Moreover, the courts have ruled that speech or conduct that becomes harassment or stalking is not protected by the First Amendment under certain circumstances, and that speech aiding or abetting a crime is likewise not protected. A true threat is where a speaker means to communicate a “serious expression of intent to commit an unlawful act of violence to a particular individual or group of individuals.” Virginia v.

But, valid time, place, or manner restrictions on content-neutral speech are constitutional if they are (1) narrowly drawn, (2) serve a significant government interest, and (3) leave open ample alternative channels of communication (Ward v.

It must be directed to incite or produce imminent lawless action and be likely to do so (Brandenburg v.




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