MANHATTAN — The Second Circuit upholds the conviction of a former law partner for two counts of cyberstalking his former partners, but reverses one of his three counts because his communications did not amount to “true threats” that are not protected by the First Amendment. Two of the counts involved thousands of messages, many of which contained explicit threats of physical harm; the messages he sent to the third person, however, “may have been distressing [but were] not sufficient to show a true threat.”
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