14 Further, as the statute requires both malicious intent on behalf of the perpetrator and substantial harm to the victim, "it is difficult to imagine what constitutionally-protected speech would fall under these statutory prohibitions." citing Petrovic, 701 F.3d at 856. Id., Contrary to William's claim, the statutory elements such as "seriously alarms" "are not esoteric or complicated terms devoid of common understanding." Osinger, supra at 945. Rather, these elements are similar to those that have led courts in other jurisdictions to uphold their criminal harassment statutes as constitutionally permissible. See, e.g., State v. Brown, 207 Ariz. 231 (Ariz. Ct. App. 2004); Bouters v. State, 659 So. 2d 235 (Fla.), cert. denied, 516 U.S. 894 (1995). Together the component parts of the statute provide adequate notice and safeguards to prevent its application to protected speech. Contrary to William's claim that the statute leaves it to the hearer of the speech to determine what conduct is criminal, the Commonwealth must prove that a defendant knew he or she was engaged in a pattern of conduct that intentionally targeted a victim for the purpose of harassment with acts of such a nature that they would cause a reasonable person to suffer substantial emotional distress. This scienter requirement undermines William's claim that he could be liable under § 43A (a) if his actions were accidental and that putative