Footnotes, 78.

For the same reason (among others), neither do these announcements fall under the defamation exception to First Amendment speech. Counterman, 600 U.S. at 80 (“Using a recklessness standard [for true threats] also fits with the analysis in our defamation decisions. As noted earlier, the Court there adopted a recklessness rule, applicable in both civil and criminal contexts, as a way of accommodating competing interests.”).