Laws, cont.

• Rarely been successfully implemented

• When used, must be "least restrictive means possible"

• "Compelling government interest" to prevent children from "indecent" exposure

• "Indecency" in the CDA defined as:

  "any comment, request, suggestion, proposal, image, or other communication that, in context, depicts or describes, in terms patently offensive as measured by contemporary community standards, sexual or excretory activities or organs."