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The report of the President's Commission on Obscenity and Pornography said: This, of course, is not a legal definition Some judges have employed the term "hard-core pornography" as a synonym for "material which can be legally suppressed".

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Mael is, in effect, the definition of hard-core applied in the marketplace. It can be argued that because of the confusion about the meaning of the term, which stems primarily from an undefined legal concept, it would be well to aft the use of the term altogether There is one genre of sexually oriented material which is almost universally sold under-the-counter in the United States: A[t] present, distinctions between materials sold openly and those sold covertly have become extremely unclear.

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