 Conflicts continue to this day over the permissible limits on free speech, both where sex is involved and more generally. The development of video and robotic technologies that allow highly realistic simulations of degrading or violent sexual acts have placed additional challenges to regulatory efforts, as these depictions do not require human performance and thus do not directly harm individuals creating the depictions. Some argue that viewing these materials should be criminalized because this conduct is wrongful and it can be the proper object of the criminal law to punish wrongdoing even when it does not harm others directly (Danaher 2017). Feminists have pointed out that drawing the line for state intervention at direct harm to others hews closely to problematic distinctions between the public and the private drawn by Millian liberals. Bracewell (2016) observes in addition that the earlier ordinances advocated by MacKinnon and others proposed damage remedies and injunctive relief rather than criminalization; the carceral turn against violent speech is more readily aligned with liberalism’s delineation of the proper role of the state as harm-prevention. Indeed, the U.S. Supreme Court decision striking down California’s statute imposing civil fines for the sale of violent video games to minors rested on the liberal view that content-based regulation of speech is impermissible,  Brown v. Entertainment Merchants Association,  564 U.S. 786 (2011).