Student speech on the Internet, cyber speech, which occurs while off-campus is a growing concern for K-12 public school officials. Parents and students have claimed that First Amendment violations occur when school officials discipline students for their speech occurring off-campus on the Internet using a personal computer and personal Internet services. However, courts vary on the applicable legal standard for cases of off-campus student Internet speech since no specific U.S. Supreme Court ruling governs the question. Therefore, courts, school administrators, and legal scholars are re-examining the notion of students" rights to freedom of speech as guaranteed by the First Amendment in the modern Internet and bullying era. Gibbs includes a recommended framework for addressing off-campus student cyber speech based upon the database of cases studied.