In 2006, thirteen-year-old Megan Meier met a teenage boy named Josh Evans on the social networking website MySpace. The two had an amicable relationship until Josh began making derogatory comments to Megan. The correspondence ultimately resulted in her suicide. Months later, “Josh” was revealed to be the collective creation of forty-seven-year-old Lori Drew, her teenage daughter, and her part-time employee, Ashley Grills. Megan’s suicide has pushed forward legislation for the criminalization of cyberbullying, which can be defined as action or behavior on the Internet intended to hurt or harass another person. This Comment discusses the issues and challenges associated with creating cyberbullying laws, from the decision to create such laws in the first place, to the difficult First Amendment restrictions posed by the “true threat” and “imminent incitement” doctrines.