In Matter of Davan L., 91 NY2d 88 [1997]) a juvenile was charged with obstructing governmental administration for interfering in a narcotics buy operation. In that case, the respondent was circling the block on a bicycle near the location of the operation. A plainclothes officer displayed a badge to the respondent and told him not to get involved and to leave the location. Instead, the respondent turned around, entered the "identified zone" and yelled, "Cops, cops ... watch out, Five-0, police are coming." (Supra, at 90.) Police officers were conducting an undercover narcotics "buy operation." During the operation, an officer observed the juvenile defendant slowly and repeatedly circling the block on his bicycle. Another officer approached the youth, identified himself as a police officer, and advised the defendant not to get involved. Nevertheless, the defendant continued to ride his bicycle in the area while yelling (at 90), "cops, cops ... watch out, Five-0, police are coming." Despite the apparent lack of direct physical force or physical interference on the part of the defendant, the Court upheld the defendant's conviction of obstructing governmental administration in the second degree. As stated by the Court (at 91): "This Court has held, and it is undisputed on this appeal by the presentment agency, that purely verbal interference may not satisfy the 'physical' component under Penal Law 195.05 (People v. Case, 42 NY2d 98, 102; see also, People v. Lopez, 97 Misc 2d 124; People v. Offen, 96 Misc 2d 147)." In discussing the specific facts of the Davan case, the Court continued: "The police activity area was confined and defined, and the juvenile was put on specific, direct notice. There was evidence that he intentionally intruded himself into the specific area of police activity and directed his warnings toward a known criminal activity and assembly at the location identified to the juvenile by the police officer." Then, significantly, the Court added: "There was also evidence that the juvenile caused a physical reaction and dispersal, escalating his conduct into an even more serious physical obstruction of governmental administration, under a plain reading and application of Penal Law 195.05." Thus, in Davan the Court of Appeals appears to have carefully avoided allowing the "independently unlawful act" component of Penal Law 195.05 to stand on its own. Rather, Davan found that a "physical" component was present in that the defendant was said to have intentionally caused "a physical reaction" which obstructs governmental administration.