Crossword Genius

Noisy beachgoer

Ross

I believe the answer is:

gull

(Other definitions for gull that I've seen before include "Cheat, hoax" , "Dupe - sea bird" , "Aquatic bird with short legs" , "Delude - seabird" , "Fool - hoax" .)

I've seen this clue in The New York Times.
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