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The advent of the Internet has made the "community standards" part of the test even more difficult to judge; as material published on a web server in one place can be read by a person residing anywhere else, there is a question as to which jurisdiction should apply. In United States of America v. Extreme Associates , a pornography distributor from North Hollywood , California, was judged to be held accountable to the community standards applying in western Pennsylvania, where the Third Circuit made its ruling, because the materials were available via Internet in that area. The United States Court of Appeals for the Ninth Circuit has ruled in United States v. Kilbride that a "national community standard" should be used for the internet, but this has yet to be upheld at the national level.

Conduct scientific research paper

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