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AO 72A (Rev. 8/82) 1990). It seems equally clear that, had Fenton hiked alone several miles into a forest and recited his diatribe only to himself, convicting him under § 115 would be tantamount to punishing his mere thoughts rather than any actual threat. So too, had he uttered the words to a close friend or relative in strict confidence, conviction under this statute would be unjustified. But here, Fenton’s words were spoken to a third party unrelated to their object, and whose relationship with Fenton was at least arguably adversarial, placing this case somewhere between these two extremes. Two courts have recently dealt with this issue. In United States v. Bellrichard, 779 F. Supp. 454 (D. Minn. 1991), aff'd, 904 F.2d 1318 (8th Cir. 1993), defendant sent a series of threatening letters, most of them directly to their intended victims,’ and was indicted under 18 U.S.C. § 876 for mailing threatening communications. One letter, however, was mailed to the girlfriend of a defendant awaiting sentencing. In that letter, defendant threatened to kill the sentencing judge. Id. at 457-58. In holding that such a communication did not constitute a true threat because there was no connection between the recipient and the intended victim, the court opined: In the present case, the postcard to Ms. Hoeper contains no request that it be communicated to the individuals allegedly threatened. There was no evidence at trial that Ms. Hoeper was likely to understand that the postcard was to be so communicated or that it was likely that it would be. Indeed, there was no evidence that Ms. Hoeper had any connection with the persons allegedly threatened which could make the language used by the defendant in his postcard to her a true threat against those persons. The specific language of the postcard should not be isolated from the whole context of the communication. No reasonable recipient, in light of the context, could interpret the defendant's statements about third parties as a true threat within the ambit of Watts. The The court upheld those convictions. Id. at 461. 8