Read the following excerpt from a US court opinion:
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or commentary which restricts application of § 3C1.1 only to situations in which the defendant directly threatens a witness or communicates the threat to a third party with the likelihood that it will in turn be communicated to the witness.”); United States v. Bradford, 277 F.3d 1311, 1314-15 (11th Cir.2002) (expressly rejecting the holding in Brooks and concluding that communicating a threat directly to a witness is not required to support application of the obstruction-of-justice enhancement); United States v. Jackson, 974 F.2d 104, 106 (9th Cir.1992) (“Where a defendant’s statements can be reasonably construed as a threat, even if they are not made directly to the threatened person, the defendant has obstructed justice.”); United States v. Capps, 952 F.2d 1026, 1028 (8th Cir.1991) ; United States v. Shoulberg, 895 F.2d 882,
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What is the most suitable continuation to the opinion? Your options are:
A. recognizing that it is not essential for there to be a direct threat of litigation in order to invoke the declaratory judgment act
B. holding that because  3c11 applies to attempts to obstruct justice it is not essential that the threat be communicated to the target
C. holding that to be actionable the words must be communicated or published to someone other than the plaintiff
D. holding that the question of recusal of a supreme court justice is to be left to the individual justice
E. holding that it is not
Reply with [A, B, C, D, E] only.