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11 The law turns on the same reasonable-person con- struct. The reasonable-reader test gauges whether a statement can reasonably be interpreted as stating actual facts, thereby ensuring that neither the least humorous nor the most credulous audience dictates the boundaries of protected speech. Milkovich v. Lorain J. Co., 497 U.S. 1, 20 (1990); Mink v. Knox, 613 F.3d 995, 1005 (10th Cir. 2010); Moldea v. New York Times Co., 22 F.3d 310, 314 (D.C. Cir. 1994); see also Golb v. Att’y Gen. of N.Y., 870 F.3d 89, 102 (2d Cir. 2017) (“[A] parody enjoys First Amendment protection notwithstanding that not everybody will get the joke.”). And the “reasonable reader” is “‘no dullard. He or she does not represent the lowest common denomina- tor, but reasonable intelligence and learning. He or she can tell the difference between satire and sincer- ity.’ ” New Times, Inc. v. Isaacks, 146 S.W.3d 144, 157 (Tex. 2004) (quoting Patrick v. Sup. Ct., 27 Cal. Rptr. 2d 883, 887 (Ct. App. 1994)). “Nor is the reasonable per- son some totally humorless drudge who cannot per- ceive the presence of subtle invective.” Patrick, 27 Cal. Rptr. 2d at 887. Instead, the reasonable reader’s per- spective “is more informed by an assessment of her well-considered view than by her immediate yet tran- sitory reaction,” particularly “in light of the special characteristics of satire,” which leverage that transi- tory reaction for rhetorical effect. Farah, 736 F.3d at 536.

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