One way to look at it could be like "Shouting fire in a crowded theater", which is not protected speech [0]. What if a newspaper persuaded people to do just that, but it itself did not do that? Basically, how far can someone stretch the imminent part of "imminent lawless action" such that it does not fall afoul of the law, but becomes operationally reliable to achieve some goal [1].
[0] https://en.wikipedia.org/wiki/Shouting_fire_in_a_crowded_the...
