to “a product’s likely use rather than to the defendant’s state of mind.” When construed in this light, the Supreme Court found the language unproblematic. By construing “primarily” in an objective fashion — with reference to a standard of how customers in general use the product rather than how any particular customer might use it — the Supreme Court avoided the sort of troubling subjectivity inherent in the Gentile and Ko-lender concepts of degree implicated by the phrases “general” and “credible and reliable.” Cf. Gentile, 501 U.S. at 1048-49, 111 S.Ct. at 2731 (“The right to explain the ‘general’ nature of the defense without ‘elaboration’ provides insufficient guidance because ‘general’ and ‘elaboration’ are both classic terms of degree.”); Kolender, 461 U.S. 352, 103 S.Ct. 1855 (<HOLDING>). Instead, in evaluating an object’s “primary
holding that essentially equivalent is unconstitutionally vague holding flag contempt statute unconstitutionally vague holding that loitering statute that had been construed by the courts to require individuals to provide credible and reliable identification to police officers was unconstitutionally vague because of the undefined nature of those subjective terms holding the term lewdness undefined in the iowa abatement statute to be vague holding factor b is not unconstitutionally vague