Second, criticism should not lapse into hate speech or otherwise endanger the safety of Muslim citizens. For example, in 2012 the American Freedom Defense Initiative posted an ad on a large billboard at a New York train platform that read: “19,250 Deadly Islamic Attacks Since 9/11/01—and Counting. It’s Not Islamophobia, It’s Islamorealism” (see image 9). Organizations such as the Anti-Defamation League denounced the ad as hate speech and as a deliberate attempt to mislead the public. The billboard’s message is dangerous because it has the potential to incite violence against Muslims by branding them as enemies who are complicit in the killing of innocent people.

Green, Todd H, The Fear of Islam_ An Intro…, loc. 80