For example, the original meme was about why someone might need a gun, and gave examples explaining what the various types of guns could be used for. In that context, Ross’s comment—which directly paralleled the language of the meme— was responding by suggesting another, far more upsetting, use to which he believed such a gun might be put. See Watts, 394 U.S. at 708 (“The language of the political arena . . . is often vituperative, abusive, and inexact.”) (citation omitted)). The comment was in the form of a rhetorical question, which identified no school where a shooting would happen. And the comment was made on a social media website that the Supreme Court has recently called “a quintessential forum for the exercise of First Amendment rights” analogous to “a street or park.” Packingham v. North Carolina, 137 S. Ct. 1730, 1735 (2017).
