mr. wilker. >> mr. chief justice, and may it please the court -- the plaintiffs have pled a plausible claim for intentional viewpoint discrimination in violation of core first amendment principles. we have done so for three interrelated reasons and we've pled it as a sole cause. this was solely the cause, not security rationale, but the sole cause of the move here was the viewpoint being expressed. >> would you have taken the same position if all that had been was the first move, that is, the move to fourth street? then there would have been about an equal distance from the pro-president demonstrators. >> i think that would be a more difficult case for us to prevail because we wouldn't have one of the prongs on which we rely, which is the disparate treatment as one of the factors we rely on to establish the inference of intent. >> well, then would you say that you would have no tenable case if they moved them just the one street over so they wouldn't be in a position to throw a hand grenade to the patio