Entrepreneurs in the "teen model" sector utilized a "non-nude" strategy. By ensuring models were technically clothed, operators argued their content was protected speech rather than illegal contraband. This created a cat-and-mouse game between webmasters and law enforcement. Legal scholars, such as Akdeniz (2008), have noted that these sites often ignored the "Dost test"—a set of federal criteria used to determine if an image constitutes "lascivious exhibition." Factors such as whether the child is fully or partially clothed, or posed in a way meant to elicit a sexual response, were often satisfied by these images, yet prosecution remained difficult due to jurisdictional issues and the rapid growth of the web.
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