Leaving aside the issue of whether the comments about Arata and Branham were grounded in hostility toward their gender (rather than hostility toward them as individuals), it seemed clear that what the OCR wants to ban here is not "written conduct" but speech. By classifying it as "conduct," the OCR hoped to bypass the First Amendment's protections.

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Quote text and notes from Wikiquote: Mike Godwin (page history), available under CC BY-SA 4.0. Source quality and labels are our own summary of what Wikiquote records.