 Content-based accounts face the challenge of determining which contents meet this standard. If the content that distinguishes hate speech from other types of speech must express, encourage, or incite hatred towards groups or individuals based on certain features, then the proponent of this view will need an account of expression. Is the speech in view that which signals the presence of a particular mental state in the speaker (i.e., hate) or that which is likely to prime feelings of animosity in a specific audience?