17 statute, 18 U.S.C. § 2261A (2012 & Supp. I 2013).9 748 F.3d at 433-434. Similarly, in Petrovic, 701 F.3d at 854-856, the United States Court of Appeals for the Eighth Circuit concluded that § 2261A was properly applied to a defendant who created a Web site with links to images of the victim nude or engaged in sex acts with him, where the sole purpose of the communications was to carry out the defendant's threats to harass and humiliate the victim if she ended their sexual relationship. As integral to the commission of the crime of cyberstalking, the defendant's communication, although speech, fell outside the purview of the First Amendment. The speech here, much as the speech at issue in Giboney, Sayer, and Petrovic, was also "integral to criminal conduct," serving only to implement the defendants' purpose to harass and cause substantial emotional distress to the Lyonses in violation 9 Section 2261A(2) of 18 U.S.C. (2012 & Supp. I 2013) defines cyberstalking, in relevant part, as follows: "Whoever - with the intent to kill, injure, harass, intimidate, or place under surveillance with intent to kill, injure, harass, or intimidate another person, uses the mail, any interactive computer service or electronic communication service or electronic communication system of interstate commerce, or any other facility of interstate or foreign commerce to engage in a course of conduct that . . . causes, attempts to cause, or would be reasonably expected to cause substantial emotional distress to . . . [that person], [an immediate family member of that person] or [a spouse or intimate partner of that person], shall be punished as provided in [§] 2261(b) of this title" (emphases added).

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