This decision is consistent with the holdings of virtually every other federal appellate court faced with a similar question. The Third Circuit went farther than any other court, however, in drawing the line between legally sanctionable true "harassment" and speech that, because of its unpopularity, is deemed "harassment" by school administrators. Although "non-expressive, physically harassing conduct is entirely outside the gambit of the free speech clause," the Court held, "there is also no question that the free speech clause protects a wide variety of speech that listeners may consider deeply offensive, including statements that impugn another's race or national origin or that denigrate religious beliefs." Warning school authorities against the use of "harassment" codes to silence speech, the Court noted that "where pure expression is involved, anti-discrimination laws steer into the territory of the First Amendment."