The Ninth Circuit has rejected a facial overbreadth challenge to the alien smuggling statute, finding that “‘encouraged’ refers to soliciting or aiding and abetting criminal conduct, and section 1182(a)(6)(E)(i) therefore applies to the solicitation or facilitation of specific unlawful activity—illegal entry or attempted entry into the United States.” The court further noted that “[t]o the extent that cases under section 1182(a)(6)(E)(i) have involved speech, that speech was accompanied by some ‘affirmative act of help, assistance, or encouragement’ that was either integral to an alien’s illegal entry or ancillary to actions ordinarily understood as smuggling.”