circulation. 458 U.S. at 759 n. 10, 102 S.Ct. 3348. These emotional and reputational harms are severe enough to render laws criminalizing the possession of child pornography constitutional in the interest of “stamp[ing] out this vice at all levels in the distribution chain.” Osborne v. Ohio, 495 U.S. 103, 109-11, 110 S.Ct. 1691, 109 L.Ed.2d 98 (1990) (noting that most of the child pornography industry is underground). The underlying inquiry is whether an image of child pornography implicates the interests of an actual minor. See, e.g., United States v. Williams, 553 U.S. 285, 289, 128 S.Ct. 1830, 170 L.Ed.2d 650 (2008) (“the child-protection rationale for speech restriction does not apply to materials produced without children”); Free Speech Coal., 535 U.S. at 258, 122 S.Ct. 1389 (<HOLDING>). The Supreme Court has stated, albeit in
holding that the first amendment does not protect obscenity or pornography produced with actual children holding that private possession of child pornography is not protected by the first amendment holding that the language of the ohio statute prohibits only images depicting actual children and thus does not violate the first amendment holding that virtual child pornography which did not use images of actual minors was protected expressive speech under the first amendment because it did not harm any real children through its production and continued existence holding that pornography depicting actual children can be prescribed whether or not the images are obscene because of the states interest in protecting the children exploited by the production process