Case: 21-51178 Document: 00516474571 Page: 13 Date Filed: 09/16/2022 No. 21-51178 The Platforms, of course, argue that their censorship somehow should be construed as speech for First Amendment purposes. We deal with this contention at length in Parts III.B, III.C, III.D, and III.E, infra. But even stipulating arguendo that censorship can enjoy First Amendment protection, it’s a far cry from the “pure speech” that’s the core concern of the overbreadth doctrine. See United Reporting, 528 U.S. at 40. At most, the Platforms’ censorship is, in the district court’s words, a “way that online services express themselves and effectuate their community standards.” That is, censorship is at best a form of expressive conduct, for which the overbreadth doctrine provides only “attenuate[d]” protection. Ibid. (quotation omitted); see also Broadrick, 413 U.S. at 614 (“[O]verbreadth scrutiny has generally been somewhat less rigid in the context of statutes regulating conduct in the shadow of the First Amendment, but doing so in a neutral, noncensorial manner.”). Tellingly, the Platforms have pointed to no case applying the overbreadth doctrine to protect censorship rather than speech. To the contrary, the Platforms principally rely on three cases. See Miami Herald, 418 U.S. 241; PG&E v. Public Utilities Commission of California, 475 U.S. 1 (1986); and Hurley v. Irish-American Gay, Lesbian and Bisexual Group of Boston, 515 U.S. 557 (1995). But all three involved challenges to concrete applications of an allegedly unconstitutional law, raised by a defendant in state court proceedings. So even if these cases supported the Platforms’ argument about their substantive First Amendment rights, they would provide no support for the Platforms’ attempt to use the First Amendment as a sword to facially invalidate a law before it has been applied to anyone under any circumstances. Second, overbreadth adjudication is meant to protect third parties who cannot “undertake the considerable burden” of as-applied litigation and whose speech is therefore likely to be chilled by an overbroad law. Hicks, 539 U.S. at 119; see also United States v. Sineneng-Smith, 140 S. Ct. 1575, 1586 13