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In People v. Gitlow (1922) 234 N. Y. 132, 136 N. E. 317, the New York Court of Appeals had occasion to interpret and apply the state statute making "advocacy of criminal anarchy" a felony. The statute defines "criminal anarchy" as " the doctrine that organized government should be overthrown by force or violence, or by assassination.... or by any unlawful means." The defendant, a "left wing socialists," plainly advocated in print the overthrow of the existing government in this country by the mass strike and the establishment in its place by revolution of a dictatorship of the proletariat.

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