so little social value, such as obscenity, that the State can prohibit and punish such expression by all persons in its jurisdiction.” Connick v. Myers, 461 U.S. 138, 147, 103 S. Ct. 1684, 1690 (1983). We recognize that the disseminations proscribed under Minn. Stat. § 617.261 could invade the privacy rights of others and that, under certain circumstances, such disseminations may be proscribed consistent with the First Amendment. See Dunham, 708 N.W.2d at 566 (rejecting a First Amendment challenge to Minnesota’s criminal harassment statute after concluding that the statute was narrowly tailored because it “only regulates speech or conduct that constitutes . . . substantial invasions of one’s privacy” and its focus was “to prohibit repeated and unwanted acts, words, or gestures that have or are intended to have a substantial adverse effect on the safety, security, or privacy of another”). But we cannot say, as a matter of law, that every dissemination regulated under Minn. Stat. § 617.261 is beyond the protection of the First Amendment as an invasion of privacy. In sum, Minn. Stat. § 617.261’s sweep is not limited to expressive conduct that is categorically excluded from First Amendment protection.3 3 Two state supreme courts have rejected arguments similar to those made by the state. People v. Austin, ___ N.E.3d ___, ___, 2019 WL 5287962, at *6-7 (Ill. Oct. 18, 2019) (rejecting state’s argument that “speech that invades privacy” should be categorically excluded from First Amendment protection); State v. VanBuren, 214 A.3d 791, 798-807 (Vt. 2019) (rejecting state’s argument that “nonconsensual pornography, as defined in [a] Vermont statute, falls outside of the realm of constitutionally protected speech for two reasons: such speech amounts to obscenity, and it constitutes an extreme invasion of privacy unprotected by the First Amendment”). 14