16 prompting incessant late-night telephone calls to their home by way of false representations, by overtly and aggressively threatening to misuse their personal identifying information, and by falsely accusing Jim of a serious crime. Where the sole purpose of the defendants' speech was to further their endeavor to intentionally harass the Lyonses, such speech is not protected by the First Amendment. "The [F]irst [A]mendment does not provide a defense to a criminal charge simply because the actor uses words to carry out his illegal purpose." United States v. Barnett, 667 F.2d 835, 842 (9th Cir. 1982). In this respect, we are guided by the reasoning of the United States Supreme Court and several circuit courts of the United States Court of Appeals. In Giboney, 336 U.S. at 498, cited with approval in United States v. Stevens, 559 U.S. 460, 468-469 (2010), the United States Supreme Court held that speech or writing used as an integral part of conduct in violation of a valid criminal statute is not protected by the First Amendment. Following the holding in Giboney, in Sayer, the United States Court of Appeals for the First Circuit held that the defendant's posting of fictitious Craigslist advertisements to induce anonymous third parties seeking casual sexual encounters to harass the victim amounted to unprotected speech integral to the criminal conduct proscribed by the Federal cyberstalking