M.L. v. R., 2021 NBCA 27, May 20, 2021, at paragraph 30:
The actus reus is established if a reasonable person aware of the circumstances would perceive the words as a threat of death or bodily harm: R. v. McRae, 2013 SCC 68,  3 S.C.R. 931. In order to make out the mens rea, an accused must have intended for the words to intimidate or be taken seriously.