and it wasn't even that there are a couple of lone protesters in worcester or springfield. there are events in worcester and springfield. there are regular protesters there every week, first of all. second of all, the crowds get much larger at the semiannual -- >> i object to you calling these people protesters which you've been doing during the whole presentation. that is not how they present themselves. they do not say they want to make protests. they say they want to talk quietly to the women who are going into these facilities. how does that make them protesters? >> your honor, the problem of course that the statute was looking to address was not with protesters per se. it was with people who had a desire to be as close to the facility doors and driveways as possible to communicate their message. the result of that was congestion around these doors and driveways. so it wasn't concern about protest. it was concern about people actually being able -- >> i would think if you tried to do a statute that distinguished between protesters and counsellors, that would be content b

conduct that was a problem, and it wasn't even that there are a couple of lone protestors in worcester or springfield. there are 13 events in worcester and springfield. there are regular protestors there every week, first of all. and second of all, the crowds get much larger at the semi-annual -- >> i -- i object to you calling these people protestors, which you've been doing here during the whole presentation. that is not how they present themselves. they do not say they want to make protests. they say they want to talk quietly to the women who are going into these facilities. now how does that make them protestors? >> your honor, the problem, of course, that the statute was looking to address was not with protestors, per se. it was with people who had a desire to be as close to the facility doors and driveways as possible to communicate their message. but the result of that was congestion around these doors and driveways. so it wasn't a concern about the protest, it was a concern about people actually being able to use -- >> and i would think, ms. miller, that if you tried to do a statute that dist