As we will see in Chapter 12, courts routinely uphold the constitutionality of state laws that target online attempts to solicit sex with a minor child. That is because speech intended to achieve an illegal purpose is not protected by the First Amendment. It is the illegal conduct, not the speech, that is made criminal. Texas has a law that makes it a crime to communicate online in a "sexually explicit" manner with a minor if the communication is intended to "gratify anyone's sexual desire." Does that law violate the First Amendment? Is it directed at "content" or "conduct"? How does a court consider First Amendment claims that a criminal law is directed at speech content? See Ex Parte Lo, 424 S.W.3d 10 (Tex. Ct. of Crim. App. 2013)