The 14 judges on the U.S. Court of Appeals for the Third Circuit who sat en banc to hear arguments on a school speech case demonstrated the difficulty in finding a unified answer to one of the case’s central questions: whether or not the word "boobies" on a breast-cancer-awareness bracelet is sufficiently lewd to be banned from a middle school.

John Freund, representing the Easton Area School District, argued that the sexual double-entendre inherent in the phrase "I ♥ boobies," which was stamped on rubber bracelets distributed by the Keep A Breast Foundation, is distracting in a middle school setting.