On February 29 and March 1, 2010, Rush Limbaugh broadcast biased and distorted news commentary as well as intimidating statements about an individual, Sandra Fluke.
On the air, he called Fluke a “slut” and a prostitute in response to Congressional testimony regarding contraception. The next day he aired these intimidating remarks:
"If we are going to pay for your contraceptives, and thus pay for you to have sex. We want something for it. We want you post the videos online so we can all watch."
In addition, this language, directed at a specific individual, meets the Supreme Court test for obscenity: it appeals to prurient interest, it depicts offensive sexual conduct (peeping Toms) and it lacks serious literary, artistic or political value.