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However, these laws are often not enforced in Japan, making them especially liable to censorship. In 2007, the Supreme Court ruled that Article 175 of the Japanese charter violated the correct to free speech. However, the court upheld Kishi's guilty verdict, and found that Misshitsu did meet the 3-part obscenity test. Because of this, the publishers were forced to restrict their e-book. Eventually, retail bookstores started to remove their porn sections. While many libertarians object to pornography and likely types of it, they do not believe banning them is a valid way to evade harm. Moreover, they argue that banning pornography is not easy methods to protect women. This view is rooted in the idea that censorship has been used to suppress women. In 1989, Japan's anti-porn laws came into the leading edge, with hundreds of doujinshi confiscated by police and shop owners arrested. The next year, the doujinshi conference Comiket had to relocate from the Makuhari Messe. Despite the difficulties, the convention welcomed over 200 thousand fans and 11,000 creators of fanworks.

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