In an important 1960 article, Harry Kalven, Jr., coined the phrase "two-level theory." As he described it, first amendment methodology classified speech at two levels. Some speech was so unworthy as to be beneath First Amendment protection: no First Amendment review was necessary. Thus the Court in chaplinsky v. new hampshire (1942) had referred to "certain well-defined and narrowly limited classes of speech, the prevention and punishment of which has never been thought to raise any constitutional problem. These include the lewd and obscene, the profane, the libelous, and the insulting or fighting words." At the second level, speech of constitutional value was protected unless it presented a clear and present danger of a substantive evil.