Ralph Ginzburg was quickly put into charges and convicted partly because he was responsible for not only production (as editor), but also promotion and distribution (as publisher) for Eros, Liaison, and the Housewife's Handbook on Selective Promiscuity. When there was no necessity to sort out the responsibility of different parties, any theory of the case could apply to him, just as the Supreme Court has done by shifting focus from the publications themselves to the way Ginzburg promoted them and found him guilty eventually.