Freedom of speech is a fundamental right protected by the First Amendment to the United States Constitution. It guarantees individuals the ability to express themselves without government interference or regulation. Understanding this right is essential for recognizing its limits and implications. One of the most significant cases related to freedom of speech is Schenck v. United States (1919), where the Supreme Court determined the limits of speech during wartime. Based on this context, which of the following is NOT considered a form of protected speech under the First Amendment?