Read the following excerpt from a US court opinion:
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70 . The dissent does not challenge our statement that the Supreme Court in Frisby expressed a special solicitude for the home. Dissent at 81. But it does imply that we are "penalizing rhetoric because it may have encouraged listeners to contact [Carpenter]." Dissent at 81. That is not what we are doing. We are instead recognizing that harassment of even public figures is actionable if the claimant can prove the elements of IIED and can prove that the intended purpose of the words was merely to harass. If Leykis had merely "encouraged listeners to blanket Carpenter with objections to the show's cancellation," his speech would not have been intended to "merely harass" and would not be actionable. 71 . Gormley v. Dir., Conn. State Dep't of Prob., 632 F.2d 938, 941-42 (2d Cir.1980) ; United States v. Lampley, 573 F.2d 783, 787
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What is the most suitable continuation to the opinion? Your options are:
A. holding that connecticut may criminally punish harassing phone calls because the statute punishes both harassing conduct and speech
B. holding that harassing conduct not sufficiently severe and pervasive where conduct would not have affected the work environment of a reasonable person
C. holding that employee failed to preserve hostile work environment claim when only timely allegation of discrimination was based on termination because termination is not itself harassing conduct
D. holding that making phone calls and sending facsimiles into the forum may be sufficient to confer specific jurisdiction
E. holding that an oral warning may be sufficient where the harassing conduct is not extremely serious
Reply with [A, B, C, D, E] only.