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I did not count the nine news organizations Melania Trump, the Republican candidate’s wife, also threatened to sue, nor the Daily Mail along with a small blogger, both of whom she actually sued in September for publishing stories containing rumors about her past.

Nor did I count when Trump threatened to sue an artist for creating a hilariously unflattering portrait of him, a conservative group called Club For Growth for running campaign ads that Trump did not like, former Republican presidential candidate Ted Cruz for running negative ads against him, or former Republican presidential candidate John Kasich and a Super PAC supporting Kasich for the same–all of which would have serious First Amendment implications. Another time, he seemed to threaten Amazon founder Jeff Bezos with tax auditswhich his lawyers promptly threatened to sue over, despite The New York Times clearly being protected by the First Amendment.

Editor’s note: This story has been updated to correctly identify Trump’s ex-wife who made rape allegations.

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Trevor Timm is the executive director of Freedom of the Press Foundation, a non-profit organization that supports and defends journalism dedicated to transparency and accountability. He is also a twice-weekly columnist for the Guardian, where he writes about privacy, national security, and the media.