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violence or unprotected speech amounting to incitement to violence. A landmark 1969 Supreme Court case Brandenburg v. Ohio rightly defined actionable incitement narrowly as speech intended and likely to cause imminent illegal action. It's not speech that arguably contributes to bad attitudes,[link widoczny dla zalogowanych], or even hatred. It's not speech that deeply upsets or outrages people. But the Brandenburg standard may not survive post 9/11 laws criminalizing political advocacy that's labeled material support for terrorism. It may not survive demands to restrict hate speech as a form of incitement. The former students whose complaint sparked the investigation at Berkeley predictably compared the offending protests, conducted in part by Muslim Student Association, to the "incitement" and "intimidation" that preceded the Holocaust. What constitutes incitement and intimidation? According to a "University of California Jewish Student Campus Climate Fact-Finding Team,[link widoczny dla zalogowanych]," Jewish students complain