Different states and countries have taken drastically different approaches towards loli materials and manga. Some criminalize it as pedophilia. Others do not want to infringe on freedom of expression. In the United States, federal law forbids the possession of child pornography. After the passage of Prosecutorial Remedies and Other Tools to end the Exploitation of Children Today, also known as the PROTECT Act of 2003, child pornography includes any obscene images that appear to depict an identifiable minor. The PROTECT Act was passed in the aftermath of a Supreme Court case that had held that completely virtual child pornography was protected free speech under the First Amendment, so long as it was not obscene. A key component of this ruling was that, because the pornography was not a visual depiction of an actual child, it was a victimless crime. After this case, Congress passed the PROTECT Act to prohibit virtual child pornography that was obscene and that was transmitted through a common carrier, transported across state lines, or of an amount that indicates an intent to distribute.