1.    The war had been going on for a long time, and the threat to domestic security was less than it was during Schenck, Frohwerk, and Debs.

2.    Frohwerk and Debs dealt with American involvement in Germany, while Abrams deals with American involvement in Russia (and thus less of a national security in Abrams).

3.    Because of Holmes’ new “Clear and Imminent Danger” test.  Zacharia Chafee, famous Harvard Law School professor, was a brilliant First Am. scholar who wrote an article in June, 1919, entitled “Freedom of Speech in Wartime.”  In this article, Chafee argued that with the “Clear and Present Danger” test in Schenck, Holmes had repudiated the “Bad Tendencies” test of Frohwerk and Debs (Dave, for reasons discussed above, thinks this is not a convincing arg. at all).  Chafee argued that the “Clear and Present Danger” test implied a close proximity between the speech and act, whereas the “Bad Tendencies” test did not.  Holmes met with Chafee, and Chafee successfully persuaded Holmes to change his view.  Thus, Holmes ingeniously came up with the “Clear and Imminent Danger” test.