Archive for the ‘erotophobia’ Category

Harvard’s Benjamin Edelman latest to be suckered by AVN’s $12B/year Figure

Wednesday, February 25th, 2009

From Professor Edelman’s “Red Light States: Who Buys Online Adult Entertainment?” published in Harvard’s  American Economic Association’s Journal of Economic Perspectives—Volume 23, Number 1—Winter 2009 

Table 1 

Adult Entertainment Subsectors 

Category 

Retail sales in 2006 

(millions of $) % Growth from 2005 

Video sales and rentals $3,622  15.4% 

Internet $2,841 13.6% 

Clubs $2,000 0.0% 

Cable/pay-per-view $1,745 34.2% 

Novelties/merchandise $1,725 15.0% 

Magazines $950 5.0% 

Mobile $39 11.4% 

Total $12,815 0.0% 

Source: “Industry Stats,” AVN Media Network (2008). 

In Professor Edelman’s study, Utah comes out as the nation’s number 1 downloader of internet pornography, but I can’t help wondering if Prof. Edelman even knows that many retailers in Utah are afraid to carry sexually explicit DVDs, even our own very tame, recognized by health professionals, erotic documentaries. Skimming his article, I don’t think so. I wonder how this information might change his conclusions…

 It’s a pity Prof. Edelman isn’t an “Art & Business of Making Erotic Films” reader, otherwise he wouldn’t have missed my mention four years ago of these two articles:

Forbes Article One

Forbes Article Two

Pity too that BoingBoing.net took down that “Porn Girth” article I fed Xeni Jardin two years ago. Some good info there about the size of the adult industry. Fortunately it’s archived at VioletBlueVioletBlue.org

Prof. Edelman shouldn’t feel embarrassed. Folks are willing to believe almost anything if it’s mentioned in the same sentence as the word “pornography.”

AP reporter David Crary was willing to believe that John Harmer was a Utah-based (Utah?) auto executive and anti-porn crusader, when in reality he’s just a republican hack.

The New York Times and dozens of other media outlets waited with bated breath for the adult industry to throw its weight into the HD-DVD v Blueray format war. (BTW, Sony’s put a very high hurdle on Blueray that very few porn companies will ever be able to leap, and won the war as well. I guess they didn’t care about losing the porn business…)

And of course lots of daring college professors tackle the porn question in books and titillating classes for credulous undergrads. After all, anything that generates $12B/year in revenue is worthy of serious critique, and if you have a problem with that, you’re obviously both a prude and critically unsophisticated.

And lastly let’s not forget those jillizionaire porn magnates that only drive their Rolls Royces on the weekend. Thanks for that one PBS!

Anyway, the $12/B figure is in print again. This time in a journal published by the Harvard B-school. American Economic Association. Never mind the only place the figure has ever appeared as original data is in the ever reliable AVN, and AVN’s source is (when asked by an enterprising Forbes reporter) “a pie chart.”

UPDATE:

Okay, I thought I should actually Benjamin’s paper, but I don’t know if I can go on after reading this:

More recently, as studios evaluated competing high-definition DVD formats HD-DVD and Blu-ray, at least some studios chose Blu-ray upon observing that adult studios favored that format 

Umm, no. Porn studio were overwhelming choosing HD-DVD because it had much lower mastering and replication costs. And as I said above, from the start Sony put lisensing hurdles on Blueray that most porn studio will never be able to clear. None the less, Blueray won the format war.

I know, I know. It’s so much more fun to think that the “adult industry” is a cabal of Rolls Royce driving moguls with their tendrils extending into every aspect of our lives. But in reality, it’s mostly a bunch of not very bright, not very good at what they do, and not any good at anything else chumps who think that the word “Negro” is going to be their salvation as sales decline.

UPDATE II

A correction via e-mail from Prof. Edelman. The article in question was not published by Harvard/Harvard B-school. It was published by the American Economic Association. My bad. Strike-throughs and corrections made above. Thanks for getting in touch, Ben!

UPDATE III

So I got in touch with Anne Norman, editor at The Journal of Economic Perspective. She’s a very nice woman and we had a nice phone chat. I asked her if there was some way I could comment on Ben’s article and she asked me if I was a member of the American Economics Association, and I explained that I was a filmmaker, and gave her my perspective on the deficiancies of the data that Ben cited in his paper. I told her that my interest was piqued when I saw Utah jumping of the map, and about my experience talking to retailers in Utah. (This especially seemed to catch her attention.)

Anyway, long story short, she invited me to submit a response for possible publication in an upcoming edition of the journal, so it looks like I’ll be reading Ben’s paper with a fine-toothed comb. At a glance, most of it looks way over my head, but just reading through the bibliography, I see some of usual suspects, so there’s almost no doubt there are a few more erroneous claims on top of the AVN $12B/year figure and format wars nonsense. Time to take off my trouble maker hat and put on my interested academic colleague mortar board. ;-)

YouTube Removes Bill & Desiree Trailer for TOS Violation

Wednesday, December 3rd, 2008

Yesterday we put up a trailer for Bill and Desiree on our YouTube account. Today YouTube deleted the video for a TOS violation. Here’s the trailer, off our own server:

 

Here’s a College Humor clip from YouTube.com that’s received over 4,000,000 views:

This is what YouTube has to say about sexuality and nudity:

YouTube is not for pornography or sexually explicit content. If this describes your video, even if it’s a video of yourself, don’t post it on YouTube.

Most nudity is not allowed, particularly if it is in a sexual context. Generally if a video is intended to be sexually provocative, it is less likely to be acceptable for YouTube. There are exceptions for some educational, documentary and scientific content, but only if that is the sole purpose of the video and it is not gratuitously graphic. For example, a documentary on breast cancer would be appropriate, but posting clips out of context from the documentary might not be.

Of course anyone who’s clicked around YouTube knows there are all sorts of “sexy” video clips on YouTube, so before we put up the trailer we clicked around a little to get an idea of where YouTube draws the line. Here’s a little of what we found.

A bit from a Lindsey Lohan movie:

 

At the end of the Lohan clip, YouTube suggest we might be interested in this Japanese schoolgirl fetishist clip:

 

At the end of the quasi-pedophiliac video, YouTube thought we might be interested in a little sex ed:

 

Then YouTube thought a testicular exam was in order:

 

And then finally this clip, mislabeled “Britney Sex Tape”:

 

After watching the above clips, you might feeling a little confused about what is and is not acceptable on YouTube. The trailer for “Bill and Desire” does not show full nudity. There are no female nipples shown, and the swell of Desiree’s breast is barely discernible between her and Bill’s bodies. There is no pubic hair and no genitals. There are no buttocks or ass-cracks. In short, there is no objective difference in the degree of nudity shown in the trailer for “Bill and Desiree” and these other clips that YouTube is hosting. But YouTube has an answer:

Please take these rules seriously and take them to heart. Don’t try to look for loopholes or try to lawyer your way around the guidelines—just understand them and try to respect the spirit in which they were created.

That clears it right up, doesn’t it. Like YouTube’s parent company Google, YouTube favors pranksterism over candor. The College Humor clip shows just as much skin as our trailer, but it’s meant as a joke, so that a-okay. Lindsey Lohan’s orgasmic moaning and groaning is okay because we know she’s faking it. The pedophiliac fetish schoolgirl clip – even the part with “POV” intercourse between the videographer and the model – is okay because she’s wearing white cotton panties and covering her breasts with her hands. The penile exam clip is just fine because it’s medical.

Oh, speaking of medical, next month “Bill and Desiree” will be playing for faculty and clinicians at the Martha Stewart Center for Center for Living at the Mt. Sinai Medical Center.

Coded Language and Knowing Looks, Part 1

Monday, November 24th, 2008

 step by step sex instruction

A couple years ago we entered into a non-exclusive distribution arrangement with a fairly well-know company that specializes in placing sexually explicit films in mainstream markets. This is the blurb they wrote for Matt and Khym: Better than Ever:

“This adult instructional guide helps married couples rejuvenate their sex lives through the erotic experiences of real-life couple Matt and Khym, who explain and then demonstrate explicit techniques for becoming better lovers.”

I was horrified.

If watching “Matt and Khym” helps rejuvenate a couple’s sex life, I think that’s great. But the above description runs against everything these movies stand for; the dissembling “educational” language; the promises that somehow the secrets to a better sex life (and a better marriage) have been magically encoded in the DVD; the idea that medicalized, educational sexuality is okay, but sexuality for the sake of its own beauty is not.

We severed our ties with the distributor and set about the months long work of tracking down and eliminating this description where ever we could find it.

But if you know where to look you can still find it. Not anywhere people actually shop for our films, but it’s still out there.

And it still bothers me.

Thank Heavens for Warm Praise (in a Cold World)

Friday, November 14th, 2008

“Latent in every man is a venom of amazing bitterness, a black resentment; something that curses and loathes life, a feeling of being trapped, of having trusted and been fooled, of being the helpless prey of impotent rage, blind surrender, the victim of a savage, ruthless power that gives and takes away, enlists a man, and crowning injury inflicts upon him the humiliation of feeling sorry for himself.” – Paul Valéry

“Impotent rage.”

That would more or less sum up my mood this morning. We can talk all we want about “independent production” and “new digital distribution models”, the simple fact remains: when you move a physical product through a physical distribution pipeline it’s a lot harder for the powers that be to fuck with you than when all they have to do is screen your work against a list of banned keywords and off-limit domain names.

Erotic writers are still be able to get there stories onto the mainstream bookstore shelves under the rubric of “erotica”, but what do you think is going to happen when the text is digital – and searchable. What do you think is going happen when Paypal starts backtracking search results the way Google is doing right now? And how about when image recognition software comes of age? Flick of a digital switch, and *poof*, we will disappear.

For years we have battled to make a place for our work at the “grown-up table”, but today I despair. Today, despite all our successes, our victories seem small and fragile. Today I question the wisdom of pouring still more time, money and hope into such a lopsided battle.

But it’s not all bad news. This morning (via Google alerts, of course) there are some people saying some very nice things about our films. I’m especially tickled to see Hot Movies for Her making Em & Lo aware of our work. I’ve been trying to get there attention for years without any success, but the Porn Librarian came through!

From the Porn Librarian on Em & Lo’s Daily Bedpost:

Em & Lo: What would you recommend for women, gay or straight, who just don’t like porn (the lighting, gynecological detail, fake boobs, bad acting), but wish they did, or wish they could get into it with their partners, or wish they could accentuate their fantasy lives with it, with something?

Porn Librarian: I would start by looking at something from Comstock Films. Tony Comstock creates these really interesting sex documentaries that star real life couples. There are lengthy interviews, so you really get to know about them before getting to the dirty part.

And a new friend, Dr. Strokes at the Swarthmore Daily Gazette:

Comstock Films are so perfect for couples even Oprah recommended them and so hot that they’re, well, molten. These are documentary-style films of real couples who tell you how they fell in love and then invite you to look in on their bedroom. Right now they have a gay feature, a lesbian feature, and two straight films (one featuring an awesome interracial couple), but once you’ve watched those and realized you can’t get enough, don’t despair! They’re coming out with more soon, including an older straight couple, which rocks. I can’t recommend this company enough.

As for the future, well I’m not quite ready to quit yet. But I do feel increasingly pinched between two possibilities:

1) Reconsidering the offers we’ve received from the biggies of the “adult entertainment” world, which would embed our films in a more established and less vulnerable distribution chain. Of course that would mean higher production quantity, which in turn would mean lower production values and diminished emotional and physical safety for the people I film. Not an especially attractive option.

2) Backing away from my commitment to explore sexuality as frankly and honestly and cinematically as I can. There are good films, and a good living to be made without showing cunts and cocks and jizz. Google rankings/listing for my non-erotic documentaries are stable, and none of those films have ever been banned.

Not even the one with the man getting his head cut off with a machete.

Google’s No Fly List. How did we get on it? How do we get off?

Thursday, November 13th, 2008

Google loves nazi racist skinheads more than sex

[blowfish] is on it. [blowback] is not. [nina hartely] is on the list. [annie sprinkle] is not. [tony comstock] is on the Google “no fly” list. [peggy comstock] is not.

In each of these cases, and many others, the common thread to whether or not a search string will auto-populate in Google’s search field is whether or not there are potentially “objectionable” websites with high rankings the search returns; so Google will “suggest” [sexual intercourse] or [sex offender], but not [sex toys] or [sex education].

Of course by “objectionable”, Google means “sexual”. [stormfront], [nazi], and [white power] all auto populate, and searches on those terms give high rankings to stormfront.org, americannaziparty.com, and whitehonor.com respectively.

It is an incredible slap in the face. Yeah, I get it. Google wants to stay out of hot water, and so they don’t want their “Google Suggests…” pointing anyone to boobies (much less cunts and cocks.) But Nazi skinheads? No problem there. Don’t be evil? How about don’t be a dickhead?

A bigger concern than the fact that there’s a list with [tony comstock] and [comstock films] on it as terms that won’t populate is the worry that somewhere inside of the Google there is a list with comstockfilms.com on it as a site they don’t want to send people to. Is that getting factored into our pagerank? Is that why our visitors on [real sex] dropped from 100-200/day to almost zero? Who can know?

And as far as I can tell, tinynibbles.com is on that list, blowfish.com is on that list, vividvideo.com is on that list, and a whole bunch of other sexually explicit sites, spanning a wide range of attitudes towards sexuality. And all of us — from goodvibes.com to buttman.com — are, in Google’s estimation, worse than racist hate sites.

I am angry. I am angry at Google, and I am angry at a world that wants to be “offended” by two men wanting to fuck each other for the rest of their lives than by the people who would kick those men’s faces in with the heels of their jackboots.

“Don’t be evil” Really? Matt Cutts or anyone else at Google: show me how I’ve misconnected the dots. I’d rather be wrong than angry. I’d rather be the one who’s lost his mind.

Are You on Google’s Secret List?

Thursday, November 13th, 2008

Google loves white supremist 
Stormfront.org is not on Google’s secret list

Spurred by Bacchus’s comment in the previous post, I’ve typed a few names into Google’s search box to see how/if they auto fill:

[comstock films]
No autofill to comstock films, but it does autofill to [comstock films podcast]. Presumably Google feels safe autofilling [comstock films podcast] because that delivers a bunch of “safe” domains as top results, where as [comstock films] delivers comstockfilms.com as a top result.

[tony comstock]
Nope, that doesn’t autofill, I guess because that delivers comstockfilms.com as a top result.

[violet blue]
[violet blue] autofills out to several things, but not to just plain old [violet blue], presumably because the top result for [violet blue] is tinynibbles.com

[john stagliano]
Again, this autofills out to several search strings, but not to just [john stagliano]. Could this be because buttman.com is the second return on the [john stagliano] search? Maybe Matt Cutts can fill us in?

[peggy comstock]
Now this one autofills at [peggy com]. But there’s nothing potentially “objectionable” in the top returns.

[vivid video]
Like [violet blue], [comstock films], and [john stagliano], it autofills out past the sorter search string to suggest longer search strings that deliver less “objectionable” websites. (If you think websites offering bit torrents of copyrighted material are less objectionable that the website of the copyright holder. Maybe we can get Cory Doctorow’s opinion on this one?)

Now I wouldn’t say this proves anything. I would say it suggests that maybe (maybe) there’s a list of “objectionable” websites down at the Googleplex, and that they’ve put some effort into making sure that those “objectionable” websites don’t end up in the returns in their Google Suggests product.

And oh, one more string. Let’s see how it autofills

[stormfront]
s t o r m f.. and thanks for the suggestion, Google. [stormfront], right at the top of the Google’s suggestions. And the first return? stormfront.org, of course. What did you think it was going to be?

Three guesses why Google is okay with search suggestions that deliver stormfront.org as a first return, but can’t bear to make suggestions that return tinynibbles.com or comstockfilms.com.

Taking the Real Sex out of [Real Sex] Searches. (Is the googlebot erotophobic?)

Tuesday, November 11th, 2008

two year real sex visitors graph for comstockfilms.com
A two year graph of the number of comstockfilms.com visitors using the search [real sex]

 Long time readers already know that our company has had an on again/off again relationship with Google. Back in late 2006 we broke the Christmas shopping season googlebug story with our post “Will Google Kill Comstock Films?

A bug in Google’s ranking algorhythms cause a whole host of independent sex-positive websites – babeland.com, goodvibes.com, tinynibbles.com, our own and others – to be massively de-ranked, right in the middle of the holiday shopping season, even when searching their own names, like [comstock films]. The story was picked up by BoingBoing, SearchEngineLand and even PBS.

After the story, our relationship with the googlebot was good till Autumn of 2007, when we started to derank on [real sex] and other productive search terms. We hadn’t changed anything, so I assumed Google must have changed something.

Save an utterly unexplainable uptick around April 17th, our google ranking stayed low throughout 2008, but our website was not especially active. But last July I noticed that although the word [real] is #5 in Google’s listing of keywords in inbound links, [real] doesn’t appear anywhere in the Googlebot’s listing for our site content keywords. That’s right, the Googlebot doesn’t see the word [real] at the home of real life, real people, real sex.

Of course my concern is more than idle curiosity. Visitors arriving to the site on the search term [real sex] made good customers, and we’ve gone from 100-200 such visitors a day to virutally none, with the decline having a noticable impact on our website-generated revenues. Why would the Googlebot go from giving us a high listing on [real sex] to almost no listing?

Well after more than a year of wondering, I think I have an answer.

Have a look at Google’s listing for our content and external link keywords, then look at the search results for [real couples sex].

There we are, right at the top. But never mind that. Look at the rest of the sites that come up. Click through a couple of pages. There’s a mix of news, shopping, and explicit sexuality sites.

Now google [real sex]. The only explicit sexuality sites that come up in the first 10 pages have [real] and [sex] in their domain names. Otherwise it’s all news and shopping domains. There’s even an link to classified ad in vietnam.craigslist.org “as seen on HBO’s real sex”, but no links to explicit sexuality sites that don’t have [real] and [sex] in their domain.

Now try [couples sex], or [female orgasm]. It’s as if the listings have been scrubbed clean of any explicit sexuality site, (save those with the relevant key words in their domain name.)

Now don’t get me wrong. I don’t think that we’re entitled to a high Google ranking on any search term, even our own name. Google is a private business, and their business is delivering relevant search results across an infinite range of possible queries. Add to that that the shame surrounding sexuality means it’s a world that’s going to have more than it’s fair share of spammers, SEO blackhatters, and generally nefarious individuals. The Googlebot isn’t in and of itself erotophobic, it is programed to cope with with the detritous of an erotophobic culture, and delivers an erotophobic result. (Actually, that’s a pretty good explanation of why Hollywood and Chatsworth do things they way they do them too.)

In that way what’s happening with Google isn’t so different from the large West Coast LGTB online video store that won’t carry DAMON & HUNTER, or ASHLEY AND KISHA because they don’t carry “porn”, or the fact OFLC that gives a pass to SHORTBUS  or DESTRICTED, but bans our little films. And it out how difficult it is to try and “stand tall” for what you believe in, both as an artist and a business that believes that honest, healthy sexuality isn’t being well represented in culture and commerce.

We could do a Sinclair Institute and comb though our site getting rid of all the naughty words, but is that really a representation of “real life, real people, real sex”? I don’t think so, or at least it’s not a representation of my sex life. My sex life is lusty and raunchy and raw, and so is the language. (When Peggy and I in bed together, we don’t say “coitus”, we say fuck. I bet you do too.)

We could go also through the site and take out the words “porn” and “pornography”, even in the posts that are strongly critical of the genre and the industry. (Hell, as long as we’re going down that road, we could even take the explicit sex out of our films and start producing for the late night cable markets.)

So where do you draw the line? How far do you bend to the realities of the market, with what you make, and how you market what you make, until you’re just working another job? I don’t know the answer.

When we started losing website sales we were able to move into other markets that weren’t so dependent on the whims of the Googlebot. But in a world that becomes more and more computerized everyday, where the flick of a digital switch — at Google, or anywhere else — can make you disappear, I’m still thinking about those searchers that Google is sending to a spam ad on VietNam.Craigslist.org instead of ComstockFilms.com.

I’m wondering how we can get them back.

And even if I can figure out what it takes, I’m wondering if I’m willing to do it.

UPDATE

Peggy and I spent some time using Google’s Adwords Keyword Tool to try and get a better idea how the Google algorythm sees ComstockFilms.com. The results were pretty distressing. Even when using only the text from our index page, the Keyword Tool returned suggestions like [cum fiesta], [bangbrothers], and [hot girls], and [anabollic]. I guess in that way, the Googlebot is sort of like the OFLC — unless you deny the erotosism of your work, you get lumped in with BangBus, Anabollic, and the rest. No film festivals exemption from the OFLC, or higher quality search returns from Google.

Educating Andrew Sullivan

Monday, June 16th, 2008

Andrew Sullivan is a senior editor at the Atlantic Monthy, and blogs politics and culture at The Daily Dish. Sometimes I send him notes. Sometimes he publishes them. Yesterday I sent him this:

To: Andrew Sullivan
From: Tony Comstock
Subject: Clitoral Anatomy

Since you continue to be fascinated with the clitoris and use it in various of your arguements, perhaps you should do a little wood-shedding on clitoral anatomy. Your information is sorely out of date:

http://news.bbe.co.uk/hi/health/5013866.stm

HTH

Here’s today’s Daily Dish clitoris post:

http://andrewsullivan.theatlantic.com/the_daily_dish/2008/06/clitoris-envy.html 

A straight man setting a gay man straight on clitoral anatomy. No wonder Peggy refers to Sullivan as “Your boyfriend, Andie.”

Gay Men Love Sucking Cock (Feminism and Pornography, Part 183)

Saturday, November 17th, 2007

Last Summer, while Peggy was on her way back from the Second Annual Feminist Porn Award, I started working on a post tentatively entitled “What Do Pornography and Feminism Have In Common, Part 3″.

I started writing it because I was genuinely surprised that MATT AND KHYM received an award. The previous year we had already had our turn at the podium for a heterosexual title, so felt sure if we were going to get an award for anything, it was going to be for DAMON AND HUNTER.

I stopped writing because I didn’t want to seem like an ingrate, and I really didn’t know where I was going to go with the post, other than to say that the criteria for “feminist porn” at The Feminist Porn Awards pretty much disqualified all of the erotic work that my wife and most of her women friends enjoy.

I started in on it again because of things I read on Petra Joy’s Blog, Erika Lust’s Blog, and Audacia Ray’s Blog about blowjobs, pornography, and feminism.

It was a long post, quoting liberally from the chapter “Seeing Around the Edge of the Frame” in Walter Murch’s book IN THE BLINK OF AN EYE. But once again I’ve shelved it.

Again I can’t explain exactly why, except to say that there’s nothing wrong with talking about why or how a filmmaker makes the films they make, but intentions and agendas only go so far.

If you’re a writer, the words have to make it onto the page; if you’re a painter, the paint has to make it onto the canvas; and if you’re a filmmaker, you’ve got to put it on the screen.

As far as blowjobs go, my understanding of feminism is that one of its central tenents is that a woman should be free to enjoy anything a man is free to enjoy. With that in mind, here are Damon and Hunter, talking about sucking dicks:






From DAMON AND HUNTER: DOING IT TOGETHER

2257, Obscenity, and the Magic Camera

Thursday, October 25th, 2007

“Adult sexual conduct is not illegal and it is in fact constitutionally protected. See, e.g., Lawrence v. Texas, 539 U.S. 558 (2003). The regulation of visual depictions of adult sexual activity is not based on its intrinsic relation to illegal conduct.”

That’s from the Sixth Circuit Court’s ruling 2257 regulations unconstitutional, and gets to the heart of why I am fascinated by, and passionate about making sexual imagery.

Some few years ago I directed a film about Hutu refugees in Eastern Zaire. The imagery from the camps themselves was appalling enough: emaciated men, women, and children dying as the camera rolled; bodies being stacked into the bed of trucks like cordwood. But also included was footage from the Hutu genocidal slaughter of their Tutsi countrymen (carried out largely by machete,) including footage of a man being murdered by decapitation and the desecration of corpses.

I thought long and hard about what shots I would and would not include this film. I wanted my audience to vividly understand the horrors that had played out, but I did not want to them to withdraw, to down emotionally. I wanted them to stay with the film, through to the end, and hoped that they would find meaning in what I chose to show them. I thought a lot about the line between enough and too much. But never, not even for a moment, did I think about whether or not the footage I chose to include was prosecutable.

By contrast, nothing I show in the films I make about sex is awful. In fact, it’s all quite wonderful! People who desire each other giving and receiving pleasure in the most intimate and delicious ways! Yet in choosing to document and then distributed these consensual, loving, pleasurable, and entirely legal acts, some how through the magical powers of the camera, I may be committing a crime. Depending on where my films are watched, and by whom, what I do may not be protected by the First Amendment, what I do may be considered obscene, what I do may be against the law.

“The regulation of visual depictions of adult sexual activity is not based on its intrinsic relation to illegal conduct.” That’s what the Sixth Circuit Court says. I don’t see how that squares with Miller v. California. I’d like to find out, but I don’t want to lose my house or go to jail.