Recently, Virginia’s Court of Appeals confirmed that so-called "swear words" are insufficient by themselves to convict for obscene or profane language. In Lofgren v. Virginia, ___ Va. App. ___ (Nov. 3, 2009), the Court reversed Lofgren’s conviction for a phone call in which he let loose a tirade against the complainant with F-bombs, and the words bitch and c-nt. The Court examined the definitions of those words and prior Virginia caselaw about obscene speech, and found that the primary purpose of Mr. Lofgren’s speech was not shown by the evidence to have been an appeal to the prurient interest.