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But competitors argued that the ordinance was in conflict with the First Amendment. A federal court ruled towards the ordinance. The case was Miller v. California. In Miller, the court outlined a basic legal simple for pornography. According to the Miller resolution, pornography must meet three necessities to be labeled as obscene. Pornography must portray sexual conduct defined by law, it must lack critical artistic or literary value, and it must appeal to a prurient interest. This court resolution lead the way for a legislative attack on pornography. Two women, Catharine A. MacKinnon and Katherine Dworkin, tried a legislative answer in 1983. Their proposed bill was opposed by the National Organization for Women.

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