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Justice Black's reference to Giboney v. Empire Storage & Ice Co. in his opinion in the case of NAACP v. Claiborne Hardware Co. was to highlight the distinction between protected peaceful boycotts and unlawful conduct that seeks to coerce individuals through violence or threats. In Giboney, the Supreme Court held that peaceful labor picketing is protected by the First Amendment, but coercive conduct that interferes with the rights of others is not. Justice Black invoked this case to clarify the limits of free speech and assembly in the context of boycotts and protests.

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