1 Elonis v. United States, is the main case on 875(c). What is the mental state Elonis needs to have with respect to whether the communication he was making would be understood as a serious expression of intent to harm? How much does it really matter if people are pretty aware of how their speech is being received? 2 Please review Criminalizing Revenge P*rn from Professors Citron and Franks. It raises the question of what kind of legislative response is appropriate. Congress has not (yet) enacted a nonconsensual pornography law. Should it enact one, and how far should it go? Should federal law focus on the element of revenge, punishing the intent to harm?