I think the goal was to provoke an angry reaction, although I hardly would go so far as to infer that he wanted anyone harmed by the reaction. But the Supreme Court has historically taken a very narrow reading on what constitutes a clear and present danger exemption to free speech; yelling "fire" in a crowded theater is the most common example, but it can also cover an expressed invitation to imminent lawless action, such as encouraging or provoking a crowd to riot. The problem is, I don't see this film as provoking an invitation to imminent lawless action. It was out for several weeks before any violence occurred, the violence happened overseas, and the violence was not being advocated for by the film. You're never going to convince this court that "imminent lawless action" is going to come out of a film just because people are offended by the message; the entire point of free speech is to defend the speech we find detestable.