I believe the current definition of fighting words is 1) the language must be delivered one-to-one, and 2) must be such as to evoke an immediate breach of peace (as opposed to simply offending the listener). _Chaplinsky vs. New Hampshire_ is (thankfully) out of date. According to _The First Amendment Book_ by Robert J. Wagman, 1991, p. 106: "In 1940 Walter Chaplinsky, a Jehovah's Witness, was distributing literature on the streets of Rochester, New Hampshire, when he created quite a stir by loudly telling everyone he encountered that organized religions are 'a racket' and by specifically condemning several major ones by name in great detail. He was arrested an eventually convicted under a state law that made it an offense to speak 'any offensive, derisive or annoying word to any person who is lawfully in any street or other public place'. When the case reached the Supreme Court in 1942 (_Chaplinsky v. New Hampshire_), the justices unanimously upheld the conviction and rejected Chaplinsky's claim that his words and actions were protected by the First Amendment...." According to _American Constitutional Law_ by Ralph A. Rossum and G. Alan Tarr, 1983, p. 379: "The Court has since [_Chaplinsky v. New Hampshire_] defined 'fighting words' narrowly. It is not enough that speech be offensive, or invite dispute, or provoke hostility among listeners: only fact-to-face person insults raise no First Amendment issues. Yet the difficulty of designing a statute confined to such insults has lead the Court to overturn convicts on overbreadth or vagueness grounds even when the speech at issue clearly constituted 'fighting words'" In _Cohen v. California_, 1971 the Supreme Court restated the description of fighting words as "those personally abusive epithets which, when addressed to the ordinary citizen, are, as a matter of common knowledge, inherently likely to provoke violent action. [...] "Finally, in arguments before this Court much has been made of the claim that Cohen's distasteful mode of expression was thrust upon unwilling or unsuspecting viewer, and that the State might therefore legitimately act as it did in order to protect the sensitive from otherwise unavoidable exposure to appellant's crude form of protest ... While this Court has recognized that government may properly act in many situations to prohibit intrusion into the privacy of the home of unwelcome views and ideas which cannot be totally banned from the public dialog ... we have at the same time consistently stressed that 'we are often "captives" outside the sanctuary of the home and subject to objectionable speech.' ... The ability of government, consistent with the Constitution, to shut off discourse solely to protect others from hearing it is, in other words, dependent upon the showing that substantial privacy interest are being invaded in an essentially intolerable manner. Any broader view of this authority would effectively empower a majority to silence dissidents simply as a matter of personal predilections." ...