Price v. City of N.Y. 15 Civ. 5871 (KPF) (S.D.N.Y. Jun. 25, 2018) a designated or limited public forum, or a nonpublic forum, the Supreme Court has directed lower courts to consider the space's compatibility with expressive activity and whether the government's general "policy and practice" shows that the forum is intended to be used for speech by the public. Paulsen v. Cty. of Nassau, 925 F.2d 65, 69 (2d Cir. 1991); see also Cornelius, 460 U.S. at 45.11 27 11 "Governmental intent is said to be the touchstone of forum analysis." Huminski v. Corsones, 386 F.3d 116, 152 (2d Cir. 2004) (quoting Gen. Media Commc'ns, Inc. v. Cohen, 131 F.3d 273, 279 (2d Cir. 1997)). In evaluating whether the government intended to create a public forum, courts may look to its "policies or regulations" The first category is the traditional public forum, including public streets, parks, and sidewalks, see Perry Educ. Ass'n, 460 U.S. at 45, which "by long tradition or by government fiat have been devoted to assembly and debate," Paulsen, 925 F.2d at 68 (quoting Perry Educ. Ass'n, 460 U.S. at 45). See also Int'l Soc'y for Krishna Consciousness, Inc. v. Lee, 505 U.S. 672, 678 (1992) (observing that traditional public forums are spaces that have "traditionally been available for public expression"). regarding use of the space. Hotel Emps. & Rest. Emps. Union, Local 100 of N.Y., N.Y. & Vicinity, AFL-CIO v. City of N.Y. Dep't of Parks and Recreation, 311 F.3d 534, 547 (2d Cir. 2002). However, "[i]ntent is not merely a matter of stated purpose." Paulsen v. Cty. of Nassau, 925 F.2d 65, 69 (2d Cir. 1991). Courts must look beyond official policy statements and evaluate 2002), the Second Circuit identified four factors that courts should use when evaluating the nature of a particular *27 property or space: (i) "whether the [property] falls within those categories of property historically deemed to be traditional public fora," (ii) "whether it is the type of property that should be so classified given its physical characteristics," (iii) "the objective way it is used," and (iv) the government's "intent in constructing and opening it to the public." Zalaski v. City of Bridgeport Police Dep't, 613 F.3d 336, 343 (2d Cir. 2010) (quoting Hotel Emps., 311 F.3d at 53637). The Second Circuit has repeatedly recognized that the "primary factor" in forum analysis is the manner in which the public space is used. See id.; Hotel Emps., 311 F.3d at 547. the government's actual practice towards the space at issue. Make the Road by Walking, Inc. v. Turner, 378 F.3d 133, 143 (2d Cir. 2004) (citing Cornelius v. NAACP Legal Def. & Educ. Fund, Inc., 473 U.S. 788, 802 (1985)); Paulsen, 925 F.2d at 69 (Government intent can be inferred from "policy and past practice, as well as the nature of the property and its compatibility with expressive activity." (emphasis added)). To that end, "[o]bjective indicia of intent to create a public forum, combined with a history of consistent practice, can overcome a bare statement of contrary purpose." Paulsen, 925 F.2d at 70 (citation omitted). In Hotel Employees & Restaurant Employees Union, Local 100 of New York, N.Y. & Vicinity, AFL-CIO v. City of New York Department of Parks and Recreation, 311 F.3d 534 (2d Cir. 28 In a traditional public forum, content-based restrictions on speech must survive "strict scrutiny" — that is, the restriction must be narrowly tailored to serve a compelling government interest. Pleasant Grove City v. Summum, 555 U.S. 460, 469 (2009); Hotel Emps., 311 F.3d at 545. In such a forum, the government may impose content-neutral time, place, and manner restrictions; however, these must be "narrowly tailored to serve a significant government *28 interest, and leave open ample alternative channels of communication." Perry Educ. Ass'n, 460 U.S. at 45. The second category is the designated public forum, which although not a traditional public forum,12 exists because "the government has taken 13