Looks like they have ruled with respect to specific federal statute, and decided that the mens rea requirement applies to threat, and not the communication. Makes sense to me. Personally, I don't care for strict liability statutes, as they oftenmake it too easy for the state to convict people for acts that truly were not criminal. Take a statute like Vandalism, which prohibits knowingly causing damages to another's prerty without consent. Without the intent requirement, an accident becomes a criminal offense.