Scarborough v. Frederick Cnty. Sch. Bd. the ambit of First Amendment protection. Engquist v. Or. Dep't of Agric. , 553 U.S. 591, 600, 128 S.Ct. 2146, 170 L.Ed.2d 975 (2008) ; Knight , 302 F. Supp. 3d at 565. And there is no allegation that Scarborough's online criticism contained vulgar, obscene, threatening, or otherwise legally objectionable content pushing it outside the realm of protected speech. 577 Defendants argue that Scarborough's allegations about the speech at issue are nevertheless too vague and conclusory to satisfy the first prong of the analysis and, by extension, survive a motion to dismiss. In support of this argument, Defendants point to Scarborough's purported failure to identify "what comments or statements were made, blocked, or deleted." (ECF No. 38 at 11.) Defendants imply that Scarborough needed to attach or include copies or excerpts of her online comments, but that is not required at this stage of the proceeding. By describing, in detail, the nature and content of the comments that she posted, Scarborough has met the required threshold. See Fed. R. Civ. P. 8(a)(2) (providing that a pleading must contain "a short plain statement of the claim showing that the pleader is entitled to relief"). Scarborough is not required, for purposes of pleading a First Amendment *577 claim related to her online expression, to provide a verbatim or hard-copy record of those statements. See Davison v. Randall , 912 F.3d 666, 675 (4th Cir. 2019) ("Although neither Davison or Randall remember the precise content of Davison's comment, Randall testified that it contained ‘accusations’ regarding School Board members' and their families' putative conflicts of interest related to municipal financial transactions, suggesting, in Randall's opinion, that School Board members had been ‘taking kickback money.’ "). Scarborough also satisfies the second element for this claim, the public-forum doctrine's application to Defendants' Facebook page. The Fourth Circuit's recent decision in Davison is instructive. In that case, the court considered whether an elected county supervisor's Facebook page 517 F. Supp. 3d 569 (W.D. Va. 2021) constituted a traditional public forum or limited public forum, triggering different levels of First Amendment protection. Id. at 681. Ultimately, the Fourth Circuit concluded that the Facebook page at issue, at a minimum, met the requirements of a limited public forum, in that the government official "swathe[d] the [Chair's Facebook Page] in the trappings of her office" by, among other things: (1) posting her official title on the page; (2) describing the page as belonging to a government official; (3) listing her government contact information; (4) linking to official government websites; and (5) posting content that had "a strong tendency towards matters related to [her] office." Id. at 680–81. Scarborough's allegations regarding FCPS's Facebook page easily clear the public-forum threshold for a social-media platform, as outlined in Davison. Unlike the Facebook page in that case, which belonged to an individual government employee, the Facebook page at issue here is an arm of the government entity itself. Moreover, Scarborough alleges that FCPS's Facebook page was registered as a "Government Organization" and continues to hold itself out as a platform for unlimited and unrestricted discussion on matters related to school operations. In sum, Scarborough has sufficiently alleged that the official FCPS Facebook page is a public forum of some kind. Scarborough has also satisfied the third element for this First Amendment claim. As the Fourth Circuit explained in Davison , where a plaintiff contends that the government has engaged in viewpoint discrimination, it is unnecessary to analyze whether the government's conduct was permissible based on the type of public forum at issue. Id. at 687. Viewpoint discrimination, which "targets" the specific views or opinions of the speaker, rather than the subject matter generally, is "prohibited in all forums." Child Evangelism Fellowship of S.C. v. Anderson Sch. Dist. Five , 470 F.3d 1062, 1067 n.2 (4th Cir. 2006) ; see also Matal v. Tam , ––– U.S. ––––, 137 S. Ct. 1744, 1763, 198 L.Ed.2d 366 (2017) (quoting 5

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