TITLE PAGE

TABLE OF CONTENTS

TABLE OF AUTHORITIES

STATEMENT OF INTEREST OF AMICI CURIAE

STATEMENT OF THE CASE

1. Facts

2. Prior Proceedings

SUMMARY OF ARGUMENT

ARGUMENT

1. THE MATERIALS SUB JUDICE ARE NOT PROTECTED BY THE FIRST AMENDMENT
   1. The Primary Concern of First Amendment Threat Law Is To Protect Political Speech

   2. The District Court Opinion Invents First Amendment Law and Diverges Dramatically From Precedent

2. THREATS OF SEXUAL VIOLENCE CAN BE TRUE THREATS
   1. The Materials At Bar Threaten Violence Against Women
      1. Scholarly Research and Survivor Reports Support the Reasonable Apprehension that the Transmissions Will Be Acted Upon According to Their Tenor

      2. Women are Targeted by the Materials At Bar as a Whole
         1. The Pornography Remains in the Case

         2. Targets of Threats Need Not Be Their Intended Recipients

         3. Women Are Specifically Targeted by the Transmissions

   2. The Materials At Bar Are Not Harmless Fantasies

3. THE DISTRICT COURT DECISION IN THIS CASE DENIES EQUAL PROTECTION OF THE LAWS TO WOMEN THREATENED WITH SEXUAL VIOLENCE

CONCLUSION

CERTIFICATE OF SERVICE

APPENDIX