“True threats of violence” that are directed at a person or group of persons that have the intent of placing the target at risk of bodily harm or death are generally unprotected.[39] However, there are several exceptions. For example, the Supreme Court has held that "threats may not be punished if a reasonable person would understand them as obvious hyperbole", he writes.[40][41] Additionally, threats of "social ostracism" and of "politically motivated boycotts" are constitutionally protected.[42]