The Humanitarian Law Project (HLP) trains nongovernmental organizations in conflict zones to avoid violent conflict. The training it provides consists of verbal and written instructionin other words, speechon the quintessentially political topic of conflict resolution. In the past, the organizations HLP has trained include the Kurdistan Workers' Party of Turkey and the Tamil Tigers of Sri Lanka, both of which have been designated "foreign terrorist organizations" by the U.S. government. Under the USA PATRIOT ACT, passed in the aftermath of the 9/11 attacks, it is a federal crime to "provide ... assistance" to such organizations, even when such assistance takes the form of speech to facilitate peace negotiations. The idea is that providing any assistance to these organizations could lend them legitimacy or free up resources for their violent activities. After the Act was passed, HLP filed suit challenging this provision as a violation of its First Amendment right to freedom of speech. The First Amendment prohibits Congress from punishing or otherwise restricting political speech, except when it is necessary to advance a compelling government interest.

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