The Transformation of Child Pornography The issue before the circuit courts was the constitutionality of the Child Pornography Prevention Act (CPPA) of 1996 in which Congress sought to modernize federal law by improving the its ability to combat child pornography. pornography in the age of cyberspace (Freedom of speech). There is a divide in the circuit courts regarding this bill, and this essay will address the discrepancy. This piece of legislation classifies an image that “appears to be” or “conveys the impression” of a minor engaged in sexually explicit acts as “virtual.” "child pornography. Such images include a photograph of a real child that can be scanned, replicated, and manipulated by computer to create a sexual photo, or a completely fake child that can be generated solely from computer graphics. Congress has recognized a loophole in child pornography law, as technological improvements have made it possible for child pornographers to use computers to "morph" or alter innocent images of real children to create a composite image showing them in sexually explicit poses in mind Congress intended (1) to ban computer-generated images that are "virtually indistinguishable" from those of real children, (2) to protect the privacy of real children whose innocuous images are altered to create sexually explicit images, and (3 ) to often deprive pedophiles of a "criminal tool" used to facilitate the sexual abuse of children. On December 17, 1999, in the case Free Speech Coalition v. Reno, the Ninth Circuit struck down the law as a content-based restriction on protected speech, not in furtherance of any compelling government interest because the prohibited images are not of actual children. According to that C... half of the document... a text of the statute "sufficiently narrow to advance the government's compelling interest in preventing harm to real children, based on proven congressional findings that virtual pornography has been used to seducing actual children into sexual activity, and then engaging in free speech safeguards” WORKS CITED: Eleventh Circuit Opinions. http://www.law.emory.edu/11circuit/nov99/Free Speech Coalition v. Reno, 198 F.3d 1083 (9th Cir. 1999), United States v. Hilton, 167 F.3d 61 (1st Cir. 1999), United States v. Acheson, 195 F.3d 645 (11th Cir. 1999), and United States v. Pearl, 89 F.Supp.2d 1237 (D.Utah 2000) . Holder v. Free Speech Coalition, Docket No. 00-795). http://www.medill.northwestern.edu/docket/features2001.html United States v. Hilton http://www.law.emory.edu/1circuit/july2001/00-2545.01a.html