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 defense counsel regarding the relationship between the First Amendment and antidiscrimination laws, like Title IX, Title VII, and Florida’s Civil Rights Act under Chapter 760. This was familiar territory for defense counsel, given that Mr. Cooper was also lead counsel in a parallel case challenging the IFA’s amendments to Chapter 760. See Honeyfund.com, Inc. v. DeSantis, --- F. Supp. 3d ---, 2022 WL 3486962, *9 (N.D. Fla. Aug. 18, 2022).

In Honeyfund, Defendants mistakenly asserted that “any holding striking down the IFA’s employment provisions would directly threaten the validity of Title VII’s protections against hostile work environments.” Id. (cleaned up). As this Court previously explained, Title VII targets conduct and only incidentally burdens speech, but the IFA does the inverse. Id. at *10 (noting that the IFA “targets speech—endorsing any of eight concepts—and only incidentally burdens conduct”). And while “it can be mostly speech that creates” hostile environments under federal antidiscrimination laws, this is only so “when such speech is both objectively and subjectively offensive and when it is sufficiently severe or pervasive.” Id. at *9. As this Court noted in Honeyfund, courts have recognized that this “severity or pervasiveness” requirement provides “shelter for core protected speech.” Id. (quoting DeJohn v. Temple Univ., 537 F.3d 301, 317–18 (3d Cir. 2008)); see also ''Davis Next Friend LaShonda D. v. Monroe Cnty. Bd. of Educ.'', 526 U.S. 629, 650 (1999) (reversing dismissal of complaint alleging student-on-student sexual