Concerning Incitement The Supreme Court has held that "advocacy of the use of force" is unprotected when it is "directed to inciting or producing imminent lawless action" and is "likely to incite or produce such action". The Supreme Court has also held that speech is unprotected if it constitutes "fighting words". Fighting words, as defined by the Court, is speech that "tends to incite an immediate breach of the peace" by provoking a fight, so long as it is a "personally abusive word which, when addressed to the ordinary citizen, is, as a matter of common knowledge, inherently likely to provoke a violent reaction". “True threats of violence” that are directed at a person or group of persons that have the intent of placing the target at risk of bodily harm or death are generally unprotected.
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