20 (1942). Speech integral to criminal conduct is one such long- standing category that is constitutionally unprotected, directly applicable to the defendants' conduct here, and permissibly proscribed by § 43A (a).12 Accordingly, the denial of the defendants' motion for a required finding of not guilty on the basis that they engaged in protected First Amendment activity was not error. 3. Sufficiency of evidence. The defendants contend that there was insufficient evidence of their joint venture to criminally harass the victims, arguing that both the "directed at" and "seriously alarms" prongs of the statute were not met. In reviewing the sufficiency of the evidence, we consider the facts in the light most favorable to the Commonwealth, see Commonwealth v. Latimore, 378 Mass. 671, 676-677 (1979), and determine whether any rational trier of fact could have found beyond a reasonable doubt all of the statutory elements. 12 To the extent that the defendants read our holding in O'Brien v. Borowski, 461 Mass. 415 (2012), to establish the principle that no constitutionally unprotected category of speech can be proscribed under G. L. c. 265, § 43A (a), unless we have explicitly articulated so in a previous case, they are misguided. We broadened the scope of our § 43A (a) analysis to expressly include true threats in Borowski only because we had specifically stated that the true threats exception did not apply in the § 43A (a) context in Welch, 444 Mass. at 94 n.14. Consequently, clarification was needed in Borowski that is not needed for other unprotected categories of speech that have never been explicitly exempted from the application of § 43A (a).

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