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statute should not be applied under these circumstances, and this count should not have been submitted to the jury. Id. at 459. In Alkhabaz, the defendant was charged under 18 U.S.C. § 875(c) for sending messages over the Internet “which expressed a sexual interest in violence against women and girls.” 104 F.3d at 1493. The messages contained stories, the content of which can only be described as horrific,® depicting in graphic detail “the abduction, rape, torture, mutilation, and murder of The Bellrichard court went on to state: The interpretation of the statute favored by the government could lead to absurd results since it does not take into account the particular context of third party threats. The First Amendment limits the reach of the statute as to third party threats by requiring consideration of the whole context of the communication. The statute should not be interpreted to cover every letter which, apart from its context, seems to threaten a person other than the addressee or letter recipient, as the government argues. For example, if a prosecutor mailed defendant's letters to another government official for analysis or review, that conduct could be covered by the statute--mailing a threat to injure the person of another. Similarly, if the court mails this opinion to West Publishing Company, having quoted verbatim the language used by defendant which is alleged to be threatening, that conduct could be covered by the statute. Also covered would be the conduct of a member of the general public, who, attending this trial of widespread interest, took notes of defendant's statements and mailed them to a family member, law professor, or newspaper for their information. Of course these results are absurd and reach constitutionally protected speech. More must be required for conviction under the statute. Conviction requires that the communication be a true threat. This means that a reasonable recipient, familiar with the context of the communication, would interpret it as a threat. It is this contextuality which prevents conviction under the hypothetical situations described. Id. at 459 (footnotes, citations and internal quotation marks omitted). 6 See id. at 1497-98 n.1 (Krupansky, J., dissenting) (setting forth one such message essentially verbatim). Because of the appalling content of this message and its publication elsewhere, I will not go into further detail here. 9 AO 72A (Rev. 8/82)