original_query: What is the significance of Harlan's consideration of litigation conduct in relation to speech?
query: What is the significance of Justice Harlan's consideration of litigation conduct in relation to speech in NAACP v. Button?
answer: Justice Harlan argued that litigation conduct doesn't have the same strong constitutional protection as speech, and that the Virginia statutes only incidentally infringed on speech.  He believed the NAACP's actions were not protected because they went beyond a typical attorney-client relationship, suggesting a lack of common interest and potential maliciousness.