United Kingdom: Sec. 18(1) of the Public Order Act of 1986 (POA) states that "a person who uses threatening, abusive, or insulting words or behaviour, or displays any written material which is threatening, abusive, or insulting, is guilty of an offence if: a) he intends to thereby stir up racial hatred, or; b) having regard to all the circumstances racial hatred is likely to be stirred up thereby." Among the panoply of other British hate speech laws is Section 5 of the POA, which makes it a crime to use or display threatening, abusive, or insulting words "within the hearing or sight of a person likely to be caused harassment, alarm, or distress thereby." Indeed, it was under this incredibly low threshold that Christian hoteliers Ben and Sharon Vogelenzang, accused by a Muslim patron of calling Muhammad a "warlord", were charged, but ultimately acquitted, in 2009. Conversely, Harry Taylor, an atheist who placed drawings satirizing Christianity and Islam in an airport prayer room, was convicted in April 2010 under Section 5 and given a six-month prison sentence.