In 2003, Barbra Streisand sued a photographer for $50 million after an aerial photo of her cliffside Malibu mansion appeared online. The lawsuit was ineffectual; not only did Streisand lose, but the ensuing publicity drew hundreds of thousands of eyes to the image, which until then had only been viewed six times.

The press called it the “Streisand effect”:  when attempts to censor information only bring it more attention. And today, President Donald Trump is grappling with the phenomenon, as his heavy-handed campaign to bury a meme — and his political opponents — has amplified the term “86 47” from a small bit of political speech to an international symbol of protest and defiance.  

Last May, while strolling on a beach on the North Carolina shore, former FBI Director James Comey snapped a photo of seashells arranged in the sand that read “86 47,” and posted the shot to Instagram. The numerals represent an abbreviated Trump protest; “86” is restaurant jargon for an item that should be removed from service or nixed, and “47” refers to the 47th president. 

The Trump administration cast “86 47” as a threat to kill the president, and within hours, Comey’s post was the right-wing media’s cause célèbre. Tulsi Gabbard, then the director of national intelligence, said Comey should be “put behind bars.” Trump himself told Fox News that the post “meant assassination, and it says it loud and clear.” The Secret Service launched an investigation. 

For his part, Comey deleted the post and issued a statement on May 15, saying, “I posted earlier a picture of some shells I saw today on a beach walk, which I assumed were a political message. I didn’t realize some folks associate those numbers with violence.”

But Trump — who had long expressed anger at Comey over the FBI’s investigation into Russian meddling in the 2016 election — did not let the post go. A little less than a year later, Comey was indicted by a federal grand jury for allegedly making threats against the president. “86 47,” the Justice Department argued, amounted to “a serious expression of an intent to do harm to President Trump.” 

The indictment came amid the Trump administration’s growing focus on political violence, targeted specifically — and, some experts argue, solely — on the president’s political opponents, usually groups and individuals deemed leftist or liberal. The White House designated the decentralized antifascist movement “antifa” a terrorist organization last year, and released a separate “domestic terrorism” memo that positions a number of speech and religious issues under that terrorism umbrella, including “anti-Americanism, anti-capitalism, and anti-Christianity.” And on Thursday, Secretary of State Marco Rubio was set to host delegates from more than 70 countries for a summit on combating “transnational far-left terrorism.”

Comey maintains that his post had no violent intent. He told Stephen Colbert last year that he saw the shell arrangement as nothing more than a “clever political message,” and argued during an appearance on “Meet the Press” this year that it was within his rights as a private citizen to post partisan messaging to his social media accounts. The federal criminal case against him remains active, though his lawyers recently filed motions to dismiss the charges, arguing that he is being prosecuted vindictively.

Democrats and political experts have lined up to defend Comey. Rep. Steve Cohen, D-Tenn., said on Facebook that he believed the indictment was nothing more than Trump using the federal government to “arrest and potentially jail those expressing dissenting views.”

“Nobody seriously believes that the former director of the U.S. Federal Bureau of Investigations is inciting violence against the president of the United States,” Peter Loge, a professor of political communication at George Washington University, told MS NOW. “That doesn’t even pass the sniff test.”

The Comey indictment is part of a pattern of retribution from Trump and his administration, Loge said. Immigration and Customs Enforcement is investigating its online critics, administration officials reportedly encouraged reprisals against individuals who posted condemnations of the late conservative activist Charlie Kirk, and, as with the frenzy over “86 47,” the president released a memorandum decrying the antifascist movement as a “rallying cry used by domestic terrorists to wage a violent assault” against the core principles of the country.

“The administration has shown that they are not necessarily afraid to take unorthodox approaches towards quashing disagreement or dissent,” Luke Baumgartner, an extremism researcher at GWU, told MS NOW. He suggested that the average American sees the Comey indictment as politically motivated.

Loge also argues that there’s an ulterior motive behind the Comey indictment: It’s a signal  to Trump’s critics in Washington that dissent will be met with prosecutorial force. 

However, in the months since the charges against Comey were filed, “86 47” has instead become a rallying cry for the anti-Trump movement and has made a variety of appearances in the nation’s capital over the past couple of months. 

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In early June, visitors to the top of the Washington Monument were greeted by an unusual sight: dead grass in the open space between the obelisk and the World War II Memorial. Upon examination, the discoloration appeared to spell out Comey’s catchphrase. The National Park Service announced that it would investigate the alleged vandalism, but did not respond to a request for comment regarding the status of the case.

The numbers then reappeared a little farther down the National Mall as members of the press and public alike flocked to the Lincoln Memorial Reflecting Pool to see its new sea-green hue. Multiple witnesses told MS NOW that an individual had drawn “86 47” in algae on the bottom of the pool, before it was ultimately scrubbed away by the cleaning staff on site. Then the message surfaced at the Great American State Fair, at an interactive graffiti exhibit within the Texas tent, Forbes reported. 

Tourists arriving for America’s 250th were greeted by the digits cast upon the side of the National Gallery of Art earlier this month, and protesters chanted the phrase as they marched down Constitution Avenue during the semiquincentennial celebration. The numbers have been spotted on protest signs, banners and flags across the district in recent months, including outside the Supreme Court. 

That latter instance led to a legal clash between the organization behind the protests, Accountability NOW USA, a group that advocates for Trump’s impeachment and removal from the presidency, and the Interior Department, which sought to ban “86 47” from material included in a planned protest that received a National Park Service permit, due to its alleged violent connotation. 

In June a federal judge disagreed with the department’s assessment. U.S. District Judge Randolph Moss ruled that the organization’s “signs and flag fall well within the heartland of protected First Amendment speech” and ordered that the park service allow protesters to use the four-digit code in their demonstrations.

Outside the district, however, federal law enforcement still appears to be taking seriously the alleged threat posed by Comey’s phrase. Last week, a man in Mattituck, New York, was reportedly interviewed by two Secret Service agents after he added “86 47” to a flag hanging above his farm, according to The Suffolk Times, a local Long Island publication.

It seems unlikely that Comey’s seashell arrangement would have inspired such a prevalent new motto for the anti-Trump resistance on its own. Comey is hardly a social media star, with under 200,000 followers, and many of his posts fail to crack even 1,000 likes.  

Instead, it appears that the Justice Department’s indictment and the Trump administration’s reaction to the post had the same effect as Streisand’s $50 million lawsuit: a surge of media coverage and a lot more attention on the very conduct that was meant to be punished. 

MS NOW Newsgathering Intern Tyler Iglesias contributed to this report. 

Adam Hudacek

Adam Hudacek is a desk associate for MS NOW covering national politics in Washington, D.C.