Yes, and as generally used and meant, it means "freedom to express any opinion". No one reasonable disagrees that you shouldn't be able to yell fire in a crowd

Yes, and as generally used and meant, it means "freedom to express any opinion". No one reasonable disagrees that you shouldn't be able to yell fire in a crowded theater. There have never been people advocating for that when they argue for free speech. Pointing out there is a restriction on causing riots or disturbances to argue that there is not truly free speech is rather meaningless. It's a 'victory' only in the most technical sense, and not one worth recognizing considering how irrelevant it is to the actual discussion, which relates to "freedom to express any opinion". Just to be clear, the claim is that the US has significantly more freedom to "express any opinion" than any other first world country does. In this context, "freedom to express any opinion" is generally referred to as "freedom of speech".