In cases where the criminalized behavior is pure speech, civil disobedience can consist simply of engaging in the forbidden speech. An example would be WBAI's broadcasting the track "Filthy Words" from a George Carlin comedy album, which eventually led to the 1978 Supreme Court case of FCC v. Pacifica Foundation. Threatening government officials is another classic way of expressing defiance toward the government and unwillingness to stand for its policies. For example, Joseph Haas was arrested for allegedly sending an email to the Lebanon, New Hampshire city councilors stating, "Wise up or die."