Fair enough! That summary probably shows why it is likely not criminal harassment, because 264 (1)spells out the bar that behaviour has to cross to be criminal harassment: it must cause the target “reasonably, in all the circumstances, to fear for their safety or the safety of anyone known to them.”
It’s not easy to prove criminal harassment in Canada and cases can fall apart based on the fact that the victim of harassment wasn’t actually scared.
On the other hand, perhaps a person could make the case that when it’s the Hell’s Angels doing the calling, it takes on a sinister tone that would cause a reasonable person to fear for their safety. Rightly or wrongly it’s probably a lot easier to make a criminal harassment case against a biker gang than against another organization. (Plus odds are at least one of those callers went farther than complaining and made a threat or something)
