The lawful definition of pornography in the U.S. evolved through decades, from the 1960s. In this period, recognizing ambiguities, the term "sexually explicit content" gained use as one of the pornography's euphemisms, but later it was determined that a distinction between pornographic and sexually explicit content is completely artificial. In "Miller v. California" the Supreme Court used the definition of pornography made by "Webster's Third New International Dictionary" of 1969 ("a depiction (as in a writing or painting) of or : a portrayal of erotic behavior designed to cause sexual excitement"). "Black's Law Dictionary" followed the Miller test and defined pornography as material that taken as a whole the average person, applying contemporary community standards, would find appealing to the interest. "Heinle's Newbury House Dictionary of American English" (2003) defined pornography as "obscene writings, pictures, or films intended to arouse sexual desire".