Price v. City of N.Y. 15 Civ. 5871 (KPF) (S.D.N.Y. Jun. 25, 2018) affirmative steps to open up [the space] for general public discourse." Johnson v. Perry, 859 F.3d 156, 172 (2d Cir. 2017) (quoting Peck v. Baldwinsville Cent. Sch. Dist., 426 F.3d 617, 626 (2d Cir. 2005)). "The government does not create a public forum by inaction or by permitting limited discourse, but only by intentionally opening a nontraditional forum for public discourse." Cornelius, 473 U.S. at 802. Examples include university meeting facilities and municipal theatres. See United Methodist Parish v. Bd. of Educ. of City Sch. Dist. of City of Newburgh, 907 F. Supp. 707, 713 (S.D.N.Y. 1995). & Visitors of Univ. of Va., 515 U.S. 819, 829 (1995); see also Ross Rinehart, "Friending" and "Following" the Government: How the Public Forum and Government Speech Doctrines Discourage the Government's Social Media Presence, 22 S. Cal. Interdisc. L.J. 781, 788-89 (Spring 2013) ("When a state opens a limited public forum but excludes a speaker who falls within the class of speakers to whom the forum is made available or whose speech concerns a subject matter for which the forum is dedicated, the state's exclusion is subject to strict scrutiny." (citing Ark. Educ. Television Comm'n v. Forbes, 523 U.S. 666, 672 (1998)). Restrictions on speech that is not within the type of expression allowed in a limited public forum must only be reasonable and viewpoint-neutral. See, e.g., Fighting Finest v. Bratton, 95 F.3d 224, 227 (2d Cir. 1996) (corrected opinion). 12 A space is presumptively a public forum if it is "generally open to the public," Widmar v. Vincent, 454 U.S. 263, 268 (1981), "designed for and dedicated to expressive activities," Southeastern Promotions, Ltd. v. Conrad, 420 U.S. 546, 555 (1975), or "has as a principal purpose ... the free exchange of ideas," Int'l Soc'y for Krishna Consciousness, Inc. v. Lee, 505 U.S. 672, 679 (1992) (citation omitted). 29 "Speech in a designated public forum is entitled to the same constitutional protection as that extended to expression in a traditional public forum, so long as the state continues to designate the forum for such use." Peck, 426 F.3d at 626. That is, in designated public forums, content-based restrictions on speech must survive strict scrutiny. See Pleasant Grove City, 555 U.S. at 469-70; Int'l Action Ctr. v. City of New York, 587 F.3d 521, 526-27 (2d Cir. 2009); Hotel Emps., 311 F.3d at 545. *29 A limited public forum is a subset of the designated public forum. It arises "where the government opens a non-public forum but limits the expressive activity to certain kinds of speakers or to the discussion of certain subjects." Hotel Emps., 311 F.3d at 545 (quoting N.Y. Magazine v. Metro. Transp. Auth., 136 F.3d 123, 128 n.2 (2d Cir. 1998)). Once a government "has opened a limited forum . . . , [it] must respect the lawful boundaries it has itself set." Rosenberger v. Rector 30 The third category is that of nonpublic forums, which consist of spaces that "the government has not opened 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 45-46. The state has more control over speech in nonpublic forums than in public forums because "its actions [in nonpublic forums] are most analogous to *30 that of a private owner." Paulsen, 925 F.2d at 69. In nonpublic forums, the government may restrict speech so long as the restrictions are "reasonable and not an effort to suppress expression merely because public officials oppose the speaker's view." Perry Educ. Ass'n, 460 U.S. at 46; Hotel Emps., 311 F.3d at 546 ("The government may restrict speech in non-public fora subject only to the requirements of reasonableness and viewpoint neutrality."). Regardless of where it occurs, however, the government's own speech "is exempt from First Amendment scrutiny." Johanns v. Livestock Mktg. Ass'n, 544 U.S. 550, 553 (2005). Instead, when the government engages in its own speech, it is permitted to "speak for itself" and to "select the views that it wants to express." Pleasant Grove 14