So the California Supreme Court held yesterday (People v. Gonzalez), interpreting Cal. Penal Code § 422 - a statute that applies to statements "made verbally, in writing, or by means of an electronic ...

So the California Supreme Court held yesterday (People v. Gonzalez), interpreting Cal. Penal Code § 422 — a statute that applies to statements “made verbally, in writing, or by means of an electronic ...