 Examples include the early use of the term "gay marriage" as opposed to "same-sex marriage" or "marriage equality," as well as the lack of recognition of bisexuality in briefs or opinions handed down by the courts.A survey of relevant terminology in LGBT-rights cases found that, excluding a brief period in U.S. Supreme Court history when bisexuals were mentioned alongside gays and lesbians bisexuality has not been mentioned in Supreme Court opinions or briefs in major LGBT rights cases, which often describe gays and lesbians as being exclusively affected by sexual orientation discrimination.While courts have begun to increasingly use the term "same-sex" in litigation involving sexual minority groups, this term is still used interchangeably with "gay", "lesbian", and "homosexual", therefore erasing the bisexual contingent.