• [119] See United States v. Francis, 164 F.3d 120, 122 (2nd Cir. 1999) (commenting that all circuits except for the Ninth Circuit have interpreted 18 USC ???875 as being a general intent crime); see also United States v. Patillo, 438 F.2d 13, 15-16 (4th Cir. 1971) (holding that a showing of specific intent is required where there is little likelihood that a statement will be received by the threate