Harmelin even though his conduct was no less serious. Like drug possession and distribution offenses, advertising and distributing child pornography is a significant crime because it “threaten[s] to cause grave harm to society.” Harmelin, 501 U.S. at 1002, 111 S.Ct. 2680 (Kennedy, J., concurring in part and concurring in the judgment). The distribution of child pornography feeds an industry that causes physiological, emotional and mental trauma to the child victims. See Osborne v. Ohio, 495 U.S. 103, 109, 110 S.Ct. 1691, 109 L.Ed.2d 98 (1990). By advertising his desire to receive and trade child pornography, Meiners directly encouraged the production and distribution of material that is created by abusing children. See United States v. Pabon-Cruz, 255 F.Supp.2d 200, 210 (S.D.N.Y.2003) (<HOLDING>). Because this is not the “rare case in which a
recognizing that the advertising statute bears a different relationship to the purpose of preventing child abuse than does the receipt and distribution statute because advertising directly encourages production of child pornography holding that an 80year sentence for production of child pornography was not disproportionate to the crime be cause of the devastating consequences of sexual abuse of children holding that trading of child pornography is distribution for purposes of  2g22b2 holding that an overbreadth challenge to a child pornography law was rendered moot by amendment to the statute holding that private possession of child pornography is not protected by the first amendment