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You can compare yelling "Fire!" in a crowded theatre to a lot of speech, for example, speech that is against a military draft. This was the original comparison.

Luckily we (the United States) prevent our government from restricting this type of speech.

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Like bhupy pointed out above, is the misinformation present directed to inciting or producing imminent lawless action and is likely to incite or produce such action?

If a speech against the draft incites some subset of those who were present to insurrection, with the intent to detain and possibly murder elected officials, then it may not be protected as free speech.

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