Provisions of the Child Pornography Prevention Act of 1996 that banned virtual child pornography were struck down in Ashcroft v. Free Speech Coalition, 535 U.S. 234 (2002). Congress passed several laws increasing the penalties for child pornography offenses, so that from 1997 to 2007, the mean sentence of child pornography offenders increased from 20.59 months to 91.30 months of confinement, an increase of 443%.[79] In 2003, Congress passed the PROTECT Act, authorizing lifetime terms of federal supervised release for child pornography offenders;[80] since U.S. Sentencing Guidelines recommend imposing the maximum term of supervised release for all sex offenders,[81] this means that a lifetime term of supervised release is recommended for all child pornography offenders.