Premise: Penthouse is a 1933 American Pre-Code crime film starring Warner Baxter as a lawyer and Myrna Loy, as a call girl who helps him with a murder case. It was directed by W. S. Van Dyke and written by Frances Goodrich and Albert Hackett, based on a novel by Arthur Somers Roche. The film was later remade as the more sanitized "Society Lawyer" (1939), without the risqué pre-Code dialogue.
Hypothesis: Society Lawyer was definitely less risque than Penthouse.