19 Nonetheless, the defendants attempt to argue that they are entitled to a required finding of not guilty on the criminal harassment charge because none of their speech constituted "fighting words," which they contend was the only form of speech punishable at the time of the offense under our interpretation of the statute in Welch. See generally 444 Mass. at 93-100. This argument is meritless. While the focus of our decision in Welch was centered on the "fighting words" doctrine, we expressly noted that "[a]ny attempt to punish an individual for speech not encompassed within the 'fighting words' doctrine (or within any other constitutionally unprotected category of speech) would of course offend our Federal and State Constitutions" (emphasis added). Id. at 99. These well-defined and limited categories of speech "are not protected because they are 'no essential part of any exposition of ideas, and are of such slight social value as a step to truth' that whatever meager benefit that may be derived from them is 'clearly outweighed' by the dangers they pose." Borowski, 461 Mass. at 422, quoting Chaplinsky v. New Hampshire, 315 U.S. 568, 572 hybrid of speech and conduct. There is content within the communications, but the very act of using the Internet as a medium through which to communicate implicates conduct. In Welch, supra at 99 n.15, we did "not suggest that incidents of harassment that consist of more than pure speech should be exempted from punishment." Here, the conduct and speech together "constituted a single and integrated" course of action in violation of a valid law. See Giboney v. Empire Storage & Ice Co., 336 U.S. 490, 498 (1949).

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