Price v. City of N.Y. 15 Civ. 5871 (KPF) (S.D.N.Y. Jun. 25, 2018) Rosenberger, 515 U.S. at 829). The district court denied the government's motion to dismiss the complaint, and later denied a government official's motion to dismiss the First Amendment claim related to blocking Plaintiff's critical comment from the official's Facebook page. See Davison v. Loudoun Cnty. Bd. of Supervisors, 227 F. Supp. 3d 605, 610-12 (E.D. Va. 2017). 35 "as a principal purpose ... the free exchange of ideas," Int'l Soc'y for Krishna Consciousness, 505 U.S. at 679 (citation omitted). 36 While Davison confronted similar issues to those present here, it is of limited assistance to this Court: there, the defendants conceded that the county's official Facebook account constituted a limited public forum, but here, *35 the City Defendants make no such concession. In any event, if forced to resolve, this Court would be inclined to find that the City's official Twitter accounts do not constitute a traditional public forum. The Supreme Court "has rejected the view that traditional public forum status extends beyond its historic confines," Ark. Educ. Television Comm'n, 523 U.S. at 678 (citing Int'l Soc'y for Krishna Consciousness, 505 U.S. at 680-81), which consist of public streets, parks and sidewalks, see Perry Educ. Ass'n, 460 U.S. at 45. See also United States v. Am. Library Ass'n, 539 U.S. 194, 205-06 (2003) ("The doctrines surrounding traditional public forums may not be extended to situations where such history is lacking."). The Court would also likely be inclined to reject the notion that the City's official Twitter pages are nonpublic forums, because by creating the Twitter accounts and interacting with the public, it has opened those forums "for expressive activity by members of the public." Hotel Emps., 311 F.3d at 546; see also Perry Educ. Ass'n, 460 U.S. at 4546. In fact, the City's official Twitter pages share many characteristics of public forums, even if not traditional public forums: Twitter is "generally open to the public," Widmar v. Vincent, 454 U.S. 263, 268 (1981); appears to be "designed for and dedicated to expressive activities," Southeastern Promotions, 420 U.S. at 555; and appears to have 37 The Court, however, need not resolve the issue now. The FAC sets forth facts suggesting that Plaintiff posted tweets in the interactive sections of two *36 Twitter accounts, under her own account name and attributed to her alone, that criticized City agencies and officials for failing to adequately serve domestic violence victims and that warned other victims of the consequences of seeking help from City agencies. Very shortly after posting the critical tweets, Obe and Brooks blocked Plaintiff from the official accounts. (See FAC ¶¶ 102-14). These allegations strongly suggest that Obe and Brooks blocked Plaintiff from the official Twitter accounts because of her critical comments and to prevent her from publicly criticizing City officials in those forums. That is, it appears that Obe and Brooks expelled Plaintiff from the official Twitter accounts on the basis of her viewpoint. See Rosenberger, 515 U.S. at 829 (stating that "viewpoint discrimination" is "an egregious form of content discrimination" in which the government "targets not subject matter, but particular views taken by speakers on a subject"). Regardless of whether it occurs in a public, designated, or nonpublic forum, viewpoint discrimination that results in the intentional, targeted expulsion of individuals from these forums violates the Free Speech Clause of the First Amendment. See Rosenberger, 515 U.S. at 820 (holding that the government is prohibited from "exercis[ing] viewpoint discrimination, even when the ... forum is one of its own creation"); Make the Road by Walking, 378 F.3d at 143 (requiring viewpoint neutrality even in nonpublic forum). Because viewpoint discrimination, such as that alleged by Plaintiff in this action, is unlawful in any forum subject to the Free Speech Clause, the Court finds that *37 Plaintiff has adequately alleged that Obe and Brooks violated her rights under the First Amendment. 17