The first ambiguity concerns the persons to be counted among potential addressees: everyone, only people to whom a phrase really 'applies,' or all those likely to be angered by having the label applied to them? Someone of French origin reacts differently to being called a 'Polack' than someone of Polish origin. … Another ambiguity is how an 'average addressee' is to be conceived … [can the same remark be punishable if directed at the one person able to respond and constitutionally protected if directed at people not able to match the speaker physically?