Kinda irrelevant, given that the go-to examples I see on Hacker News of this happening in the EU and UK are either actual death/violence threats etc. (which are also not protected speech in the USA) or also not upheld in higher European courts.

https://en.wikipedia.org/wiki/United_States_free_speech_exce...

Incitement is only illegal when "directed to inciting or producing imminent lawless action".

And? I didn't say anything about "incitement", I said "actual death/violence threats", because I meant people making actual threats of violence up to and including death, are the actual things tweeted in the most commonly seen examples given on Hacker News (besides the aforementioned "also not upheld" that the commenter I was replying to tried to use to justify when Americans get arrested for tweets).