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STATE OF NORTH CAROLINA v. PHILLIP ERVIN HIGGS,
COURT OF APPEALS OF NORTH CAROLINA 2006 N.C.
May 16, 2006, Filed

A Pitt County jury found Defendant Phillip Ervin Higgs guilty of indecent exposure and taking indecent liberties with a child. On 21 April 2005, the trial court entered judgments sentencing Defendant to sixty days imprisonment for the offense of indecent exposure and to a suspended sentence of nineteen to twenty-three months imprisonment for taking indecent liberties with a child.

Whether the trial court committed reversible error in allowing the testimony of Lauren-child witness pursuant to Rule 404(b) of the North Carolina Rules of Evidence?

Observation and Holding:

When evidence of a defendant’s other sex offenses is offered for a proper purpose, “the ultimate test for determining whether such evidence is admissible [under Rule 404(b)] is whether the incidents are sufficiently similar and not so remote in time as to be more probative than prejudicial under the balancing test of N.C.G.S. § 8C-1, Rule 403.” State v. Boyd, 321 N.C. 574, 577, 364 S.E.2d 118, 119 (1988). Here, the following similarities exist between the incidents: (1) young females were involved; (2) Defendant was more than thirty years older than each of the females; (3) Defendant offered both females rides in his vehicle; (4) Defendant was involved with each female’s family in that he provided a free home for Lauren’s family and provided assistance with basketball to the child’s brother; (5) Defendant exposed his erect penis to both females while they were in his vehicle; and (6) Defendant told each female not to tell anyone what he had done. Further, one of the incidents of indecent exposure involving Lauren occurred on the same day as the incident involving the child. The other incidents of indecent exposure involving Lauren occurred with within days of the incident with the child.

Defendant does not argue the incidents with Lauren were not sufficiently similar to the incident with the child, nor does he argue the incidents lacked the necessary temporal proximity. Rather, Defendant argues the admission of Lauren’s testimony unduly prejudiced him because Lauren’s direct testimony covered more pages in the transcript than the direct testimony of the child and the acts alleged by Lauren were more egregious than the act alleged by the child. The admission or exclusion of evidence under Rule 403 “is within the sound discretion of the trial court, and the trial court’s ruling should not be overturned on appeal unless the ruling was manifestly unsupported by reason or [was] so arbitrary that it could not have been the result of a reasoned decision.” State v. Hyde, 352 N.C. 37, 55, 530 S.E.2d 281, 293 (2000) Here, before allowing Lauren to testify, the trial court excused the jury, heard the voir dire testimony of Lauren to determine its substance, and then considered arguments of counsel before overruling Defendant’s objection to the admission of Lauren’s testimony. Further, the trial court gave a limiting instruction to the jury regarding Lauren’s testimony. Although the trial court did not make a specific finding that the probative value of the evidence outweighed its prejudicial effect, the procedure that was followed demonstrated the trial court conducted the balancing test under Rule 403 of the North Carolina Rules of Evidence. As such, we conclude the trial court did not abuse its discretion in allowing Lauren’s testimony.

Disclaimer:

These summaries are provided by the SRIS Law Group.  They represent the firm’s unofficial views of the Justices’ opinions.  The original opinions should be consulted for their authoritative content.

The internet can be a fun and adventurous place for kids, it is amazing! You can go online and upgrade your child’s reading skills, play educational games, type and other beneficial things to learn that will enhance their growth of learning. Then, again it can be a scary place, you can’t watch your child 24 hours a day, you can’t protect them from everything but you are for sure going to try.

Internet porn will never go away, no matter how much you despise it. In fact it is a billion dollar industry; it is without a doubt one of the all time money makers of the world. Sex sells, it just do I mean naked women and men doing their thing are natural, but it is immoral to display it in front of millions of people. And one of those millions could be your child! It’s all over the web and damn near impossible to avoid.

There’s easy access to some of these porn sites, all you have to do is check a box that says you are 18 and older and you are in. Though you cannot be there every single minute there are ways to prevent your child from ever setting eyes on such explicit content. You can block R rated, XXX rated sites without even being there to do it and have that peace of mind in knowing that your child is safe when browsing the web.

When online your child can be protected and enjoy the internet like a child is suppose to. There are softwares that block viruses, spyware and certain websites; you can set your computer to certain restrictions to block out sites as well, but when you want ultimate protection than you will need porn blocker software. This software is like a steel gate against adult websites if someone tries to get through it will immediately deny the request, therefore making it safer to browse the internet.

Investing in a porn blocker is the best thing you can do for your family, it is really effective if you think that someone you know or love is addicted to pornography, it is a serious concern and it should not be taken lightly. Provide yourself with the comfort in knowing that you don’t have to linger over your child’s shoulder worrying about adult rated content.

It is good to monitor what your child does and who they are talking too while online. Be careful and from time to time checkout the history on your computer.

COMMONWEALTH vs. HAROLD KAUPP.

SUPREME JUDICIAL COURT OF MASSACHUSETTS

453 Mass. 102

January 16, 2009, Decided

Police impounded it based on alleged probable cause to believe it contained child pornography because the first seized unauthorized computer with the open share file had such material. A police officer obtained a search warrant to search defendant’s unauthorized computer; child pornography was eventually found there.  The trial court denied his motion to suppress evidence and he was convicted of possession of child pornography in violation of Mass. Gen. Laws ch. 272, § 29C.     

Issue:

Whether there was probable cause to search the defendant’s private files?

The court held that “in reviewing a finding of probable cause, the affidavit “should be interpreted in a commonsense and realistic fashion and ‘read an inference drawn from the affidavit, “if not forbidden by some rule of law, need only be reasonable and possible; it need not be necessary or inescapable.” After reviewing Officer Maglio’s affidavit, we conclude that the affidavit, read as a whole and in a nontechnical manner, does not establish probable cause to believe that child pornography was located among the defendant’s private files. The portions of the affidavit suggesting that the defendant’s private files contained child pornography consisted of (1) the fact that both Joester and Sinister had a copy of the recently released movie Spiderman, suggesting that the movie had passed from one computer to another; (2) the fact that child pornography had been observed in Joester’s open share; and (3) Officer Maglio’s statement that the defendant “could not guarantee that there were not any child pornographic images stored in electronic format within his computer.” None of these facts, even when considered together, provided a “substantial basis” to believe that the defendant’s private files contained child pornography.”

With respect to the presence of the Spiderman movie on both computers, the inference urged by the Commonwealth is simply too attenuated. The presence of Spiderman on both computers bears on probable cause only if it may reasonably be inferred that sharing an electronic copy of a commercial movie suggests an interest in sharing child pornography. Such an inference is not reasonable. The fact that the defendant could access child pornography does not advance the Commonwealth’s contention that the defendant copied child pornography from Joester onto his computer.  Thus, while it could reasonably be inferred that the defendant was intentionally ambiguous, such an inference, standing alone, does not provide a “substantial basis” for concluding that child pornography could be found on Sinister.

The probable cause standard and the forgiving eye with which courts read affidavits in support of search warrants provide law enforcement agents with sufficient leeway to demonstrate that the items sought are reasonably expected to be in the place to be searched. Nevertheless, the ability to access child pornography stored on Joester and the defendant’s ambiguous statement did not constitute a “substantial basis” for concluding that the defendant stored child pornography in his private files. At best, the affidavit established a “strong reason to suspect” that the defendant’s private files contained child pornography. This was insufficient.

Thus the order denying the defendant’s motion to suppress is hereby vacated and the judgments of conviction are reversed.

Disclaimer:

These summaries are provided by the SRIS Law Group.  They represent the firm’s unofficial views of the Justices’ opinions.  The original opinions should be consulted for their authoritative content.

Virginia Child Porn Laws  & Penalty

The primary Virginia child porn law is 18.2-374.1:1.  The Federal child porn laws used primarily to prosecute defendants in Virginia are 18 U.S.C. 2256 & 18 U.S.C 1466A.  The Virginia child porn laws are very strict.  The penalty for violating the child porn laws in Virginia can result in very lengthy jail sentences.  It is critical to have a skilled and experienced Virginia child porn defense attorney if you are being charged with possession, receipt or distribution of child pornography in Virginia.

The primary Virginia Child Pornography Law is 18.2-374.1:1 states: Possession of child pornography; penalty.

A. Any person who knowingly possesses any sexually explicit visual material utilizing or having as a subject a person less than 18 years of age shall be guilty of a Class 6 felony. However, no prosecution for possession of material prohibited by this section shall lie where the prohibited material comes into the possession of the person charged from a law-enforcement officer or law-enforcement agency.

B. The provisions of this section shall not apply to any such material which is possessed for a bona fide artistic, medical, scientific, educational, religious, governmental, judicial or other proper purpose by a physician, psychologist, sociologist, scientist, teacher, person pursuing bona fide studies or research, librarian, clergyman, attorney, judge, or other person having a proper interest in the material.

C. All sexually explicit visual material which utilizes or has as a subject a person less than 18 years of age shall be subject to lawful seizure and forfeiture pursuant to 19.2-386.31.

D. Any person convicted of a second or subsequent offense under this section shall be guilty of a Class 5 felony.

Under federal law (18 U.S.C. §2256), child pornography is defined as any visual depiction, including any photograph, film, video, picture, or computer or computer-generated image or picture, whether made or produced by electronic, mechanical, or other means, of sexually explicit conduct, where  

the production of the visual depiction involves the use of a minor engaging in sexually explicit conduct; or
the visual depiction is a digital image, computer image, or computer-generated image that is, or is indistinguishable from, that of a minor engaging in sexually explicit conduct; or
the visual depiction has been created, adapted, or modified to appear that an identifiable minor is engaging in sexually explicit conduct.  

Federal law (18 U.S.C. §1466A) also criminalizes knowingly producing, distributing, receiving, or possessing with intent to distribute, a visual depiction of any kind, including a drawing, cartoon, sculpture or painting, that

depicts a minor engaging in sexually explicit conduct and is obscene, or
depicts an image that is, or appears to be, of a minor engaging in graphic bestiality, sadistic or masochistic abuse, or sexual intercourse, including genital-genital, oral-genital, anal-genital, or oral-anal, whether between persons of the same or opposite sex and such depiction lacks serious literary, artistic, political, or scientific value.

Do not delay contacting a skilled Virginia child pornography defense lawyer to defend you.

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The World Wide Web has become a very generous information portal. Everything that you need can be found here from the silliest to the most serious research. You also have plenty of materials that you can use. You have e-books, videos, photos, and audio files. Simply put, the Internet can be a helpful resource—to a certain extent. When it introduces problems such as porn addiction, it becomes detrimental, more so when it affects your kids. You need to start the process of breaking porn addiction immediately. The good news is that there are a number of great ways on how to stop porn addiction.

1. Develop a completely new interest for your kid. One way of breaking porn addiction is to limit his exposure to sources of pornographic materials such as televisions and PCs. You can encourage him to participate in outdoor activities, such as sports, music, arts, or hobbies. You can perhaps bring him to a museum or watch ball games together. It may take a while before he will get used to the new activities—and he can even be resentful—but if you really want to stop porn addiction, you need to be very patient and persevering.

2. Get to know his friends. He may be a good boy inside your home, but you really don’t know how he acts when he’s with his friends. You can also stop porn addiction by getting to know the other children he usually spends time with. If they are into porn, there’s a good chance that they will or have already influenced your kid to it. Besides the kids, be friendly with their parents too. You can ask them about their children and how they are in their respective homes. When it comes to breaking porn addiction, prevention will always be better than cure.

3. Keep tabs on computer use. Of course, if you need to stop porn addiction on the Internet, you need to tackle the source: the computer. You may want to download parental controls, which will limit the time of use and the websites that can be checked out by your kids. If he has his own computer, you can set up remote networking, where you can view the web pages he’s visiting, as if he were using your own PC. There are also Internet filters. If you can, you can sit beside them as they visit web pages.  

4. Talk but never confront. There’s a difference between being confrontational and being more open to communication. Usually, the former is a one-way street. Moreover, it will only prevent you from further breaking porn addiction, since the child will be more afraid to talk about it to you. If you believe that you don’t have enough capacity to talk about porn addiction to them, you can ask help from a professional like a sex therapist or a counselor.

Parents will always be responsible to the actions of their children. Never be afraid to go to great lengths just to stop porn addiction in your household.

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Legal classifications of child pornography usually include sexual pictures involving both prepubescent and post-pubescent teenage minors and computer-created images that seem to include all of them. Most possessors of child pornography who are arrested are discovered to own images of prepubescent children; possessors of porno images of post-pubescent children are less likely to be prosecuted, even though those pictures also fall within the statutes. Legal definitions of child pornography usually contain sex images involving both prepubescent and post-pubescent adolescent children and computer-made images that seem to involve them. The majority of possessors of kid pornography that are caught are found to own pictures of prepubescent children are less probably prosecuted, despite the fact that those pictures also fall within the laws.

Within federal regulation, child porn is understood to be any visual depiction, which includes any photograph, movie, video, picture, or computer or computer-produced image or picture, whether created or produced by electronic, mechanical, or some other means, of sexually explicit conduct, in which the following actions are being applied. First of all, the creation of the visual depiction involves the use of a minor engaging in sexually explicit actions. Next is the visual representation is a digital image, computer image, or computer-generated image that is, or is indistinguishable from, that of a minor participating in sexually explicit actions. Lastly, the visible representation has been made, adapted, or modified to appear that an recognizable minor is participating in sexually explicit actions.

The web has escalated the problem of child porn by increasing the amount of material accessible, the efficiency of its distribution, and the ease of its availability. Particularly, the Internet allows entry to vast amounts of pornographic photographs from around the world. At the same time, it additionally makes pornography instantly available at any time or location.

It allows porn to be accessed (apparently) anonymously as well as secretly. One of the greater issues that this venue causes is that it further allows for direct communication and picture sharing between users, at the same time providing porn relatively cheaply. It additionally provides pictures that are of high digital quality, do not deteriorate, and can be conveniently stored. What makes it more difficult to eradicate is its ability to offer a variety of formats (pictures, movies, sound), along with the possibility of real-time and interactive encounters. Last but not the least, it permits entry to electronic images which have been altered to create composite or virtual images (widely known as morphing).

The lives of children used through child porn are forever downgraded, not only by the molestation, but through the permanent record of the exploitation. Once sexual exploitation happens, the molester may document these encounters on film or video. This proof could then become the “ammunition” required to blackmail the kid into further submission, which is necessary to carry on the relationship and maintain secrecy. These recorded images also permit molesters to “relive” their sexual dreams. The only approach to put an end with this abominable act is to stop these molesters and make sure that all media related products that have to do with child pornography must be put to garbage.

THE PEOPLE, Plaintiff and Respondent, v. DAVID NAURATH, Defendant and Appellant.
COURT OF APPEAL OF CALIFORNIA, FIFTH APPELLATE DISTRICT
October 1, 2010, Filed

On June 18, 2007, police responded to a report of marijuana growing in an apartment in Bakersfield, California. Appellant David Naurath resided at the apartment. During the search, police seized evidence of marijuana cultivation, as well as a computer tower, compact discs (CDs), and a computer flash memory drive. The computer was located in the living room of the apartment. On January 18, 2008, appellant entered a plea to a charge of cultivating marijuana. During his search of the computer for evidence of marijuana cultivation, Detective Winslow came across numerous images that appeared to contain child pornography. Appellant was convicted of one count of distributing obscene matter depicting a person under the age of 18 years engaging in or simulating sexual conduct (Pen. Code, § 311.1, subd. (a)).

Issues:

Whether the trial court erroneously failed to give an instruction on attempted violation of Penal Code section 311.1?
Whether the trial court abused its Evidence Code section 352 discretion in admitting into evidence “chat logs” of appellant’s on-line communications with others involving sexual matters?
Whether the prosecutor committed misconduct in his closing argument to the jury?

Observation and Holding:

It is well settled that in criminal cases, even in the absence of a request, the trial court must instruct on the general principles of law relevant to the issues raised by the evidence. The material distributed by appellant depicts males who clearly appear to be under the age of 18. Furthermore, even if we were to assume that the court erred in not instructing on attempt, we see no reasonable probability that appellant’s jury would have concluded that none of the distributed images depicted a subject under the age of 18, and therefore we see no reasonable probability that appellant would have obtained a more favorable outcome if an attempt instruction had been given.

Under Evidence Code section 352, the trial court enjoys broad discretion in assessing whether the probative value of particular evidence is outweighed by concerns of undue prejudice, confusion or consumption of time. The court observed that even though the chat logs hold little probative value in determining whether the defendant knew the age of the males depicted in the images, it is admissible to show that the defendant is the one who sent the images and he had dominion and control over the computer. The fact that the computer was registered to appellant, the fact that the screen name Lookn4ym2love was registered to appellant’s AOL account, and the stipulation that appellant lived at the apartment were evidence that appellant was a likely user of the Lookn4ym2love screen name, but the defense was that other persons had access to that computer and screen name. The chat logs were significant evidence that appellant (as opposed to possibly someone else who may have had access to the computer) had a sexual interest in the physical appearance and sexual behavior of young males. The chat logs showed that someone who called himself Dave and who described himself as being the same age as appellant and as physically resembling appellant had a sexual interest in the physical appearance and sexual behavior of young males. The defense, through its sole defense witness Onstot, presented testimony that others could use the computer and screen name, but there was no defense evidence that any of those other persons were named Dave or resembled appellant in age and appearance, or had a sexual interest in the physical appearance and sexual behavior of young males. Appellant argues that the court could have redacted the chat logs to make them less prejudicial. He makes no showing, however, that he ever proposed redactions which might have redacted simply what he deemed to be a few of the most egregious portions of the chats.

A defendant may not complain on appeal of prosecutorial misconduct unless in a timely fashion, and on the same ground, the defendant objected to the action and also requested that the jury be admonished to disregard the perceived impropriety.

Disclaimer:

These summaries are provided by the SRIS Law Group.  They represent the firm’s unofficial views of the Justices’ opinions.  The original opinions should be consulted for their authoritative content

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THE PEOPLE, Plaintiff and Respondent, v. THOMAS JOSEPH KUREY, Defendant and Appellant.
COURT OF APPEAL OF CALIFORNIA, SECOND APPELLATE DISTRICT, DIVISION TWO
March 28, 2001, Decided

The trial court entered an order revoking defendant’s probation for violation of Pen. Code, § 311.11 (possession of child pornography, knowing that the matter depicts a person under the age of 18 years personally engaging in or simulating sexual conduct). A sheriff’s deputy had searched defendant’s computer, and discovered movie clips purchased from a commercial Web site, depicting young male and female individuals engaged in sexual activity.

Issues:

Whether the finding of a probation violation was unconstitutional?
Whether evidence of “apparent age” should be restricted to that which is competent to establish true chronological age?
Whether the trial court should have sustained appellant’s objection to the testimony of Ms. Ming?
Whether the evidence was insufficient to show that Kurey had knowledge that the actors were under 18 years of age?

Observation and Holding:

As to the constitutional infirmity, the court observed the California statute applies to the possession of material “the production of which involves the use of a person under the age of 18 years, knowing that the matter depicts a person under the age of 18 years personally engaging in or simulating sexual conduct.” The California statute thus requires a real minor and also requires knowledge of minority on the part of the perpetrator. There is no constitutional infirmity in section 311.11 similar to that found in Free Speech.

As to the appearance evidence the court observed that appearance evidence as proof of age has been received in prior California cases. In People v. Montalvo the court discussed in dictum the proof necessary to satisfy the element of age, noting that it was not limited to documents of actual age. Instead, in every case such evidence [corporal appearances] should be accepted and weighed for what it may be in each case worth. In particular the outward physical appearance of an alleged minor may be considered in judging his age.”

As to the defendant’s insufficient evidence of knowledge of minority the court observed in the case at bar, the trial judge had his own observations of the video clips as well as the expert testimony of Ms. Ming. This constituted substantial evidence that the persons depicted were in fact under the age of 18. To prove that Kurey had knowledge that the matter depicted a person under the age of 18 years personally engaging in or simulating sexual conduct, in addition to the above evidence, the trial judge also had the testimony of the investigator that when asked how old he believed the subjects on the video to be, appellant answered that he hoped they were 18, but “I believe they are under 18.” The burden of proof in a probation revocation hearing is a preponderance of the evidence. Kurey’s own statement is sufficient to prove that he had knowledge of the minority status of the actors in the video clips he possessed.

The order of the trial court is affirmed.

Disclaimer:

These summaries are provided by the SRIS Law Group.  They represent the firm’s unofficial views of the Justices’ opinions.  The original opinions should be consulted for their authoritative content

In the Matter of Clint L. Taylor, Petitioner, v New York State Division of State Police, Respondent.

SUPREME COURT OF NEW YORK, APPELLATE DIVISION, THIRD DEPARTMENT

April 20, 2006, Decided

April 20, 2006, Entered

Facts:

Petitioner, a State Trooper, was served with charges and specifications alleging that on six occasions between April 1999 and July 1999, he purchased subscriptions to Web sites containing child pornography in violation of a State Police regulation prohibiting State Troopers from knowingly and willingly violating any law of the State.  No child pornography was discovered on the trooper’s computer, although three erotic photos were discovered. Those photos were not admitted into evidence.  At the conclusion of a hearing before a panel of three commissioned officers from respondent, the petitioner was found to have violated Penal Law §§ 263.11 and 263.16. This determination was confirmed and petitioner was dismissed from his employment. This CPLR article 78 proceeding was thereafter transferred to this Court pursuant to CPLR 7804 (g).

Issue:

Whether the substantial evidence does exist to support the conclusion that the petitioner violated Penal Law §§ 263.11 and 263.16?

The Court states that the Hearing Panel’s determination was grounded upon substantial evidence.  “Substantial evidence has been defined as ‘ “such relevant proof as a reasonable mind may accept as adequate to support a conclusion or ultimate fact”.  Here, it was demonstrated that petitioner paid for access to the Web sites which enabled him to exercise control over the images, including viewing, storing or deleting them. While petitioner correctly asserts that the Hearing Panel impermissibly relied upon a photograph which was not admitted into evidence and which indicated a use beyond the charged period, the relevant standard of proof was still met since the consideration of the photograph did not deprive petitioner of a fair hearing.  In so finding, we do not address whether the evidence presented would be sufficient to support a criminal conviction alleging a violation of the Penal Law.

Conclusion:

Hence this court confirmed that the determination of the state police department.

Disclaimer:

These summaries are provided by the SRIS Law Group.  They represent the firm’s unofficial views of the Justices’ opinions.  The original opinions should be consulted for their authoritative content.

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ROGER DONOVAN FREEMAN v. COMMONWEALTH OF VIRGINIA

COURT OF APPEALS OF VIRGINIA

FACTS:

The Circuit Court of the City of Danville, Virginia, denied defendant’s motion to suppress evidence and convicted him of carnal knowledge of a minor, statutory rape, two counts of sodomy, participating in child pornography, possession of child pornography, contributing to the delinquency of a minor, and possession of marijuana with the intent to distribute. Defendant appealed.

ISSUES:

The issue here is whether the search warrant and affidavit are compliant with statutory requirements in terms of probable cause requirement and specificity requirement.

DISCUSSION:

A presumption of validity attaches when a search is conducted pursuant to a warrant issued by a neutral and detached magistrate or judicial officer. Therefore, where the police conduct a search pursuant to a judicially sanctioned warrant, the defendant must rebut the presumption of validity by proving that the warrant is illegal or invalid.

Code § 19.2-54 expressly prohibits issuance of a “general warrant for the search of a house, place, compartment, vehicle or baggage.” So long as the search warrant describes the objects of the search with reasonable specificity, it complies with the dictates of the Fourth Amendment.

The determination whether the warrant possesses the requisite degree of specificity requires a fact-specific, case-specific analysis. In the present case, warrant was issued in relation to the “Production, Sale, Possession, Etc. Of Obscene Items,” supported by an affidavit that specifically enumerated the things or persons to be searched for, all items reasonably related to the particular offenses. Thus, the pertinent instruments sufficiently detailed the objects that were the subject of the search, together with a compelling nexus to the offenses under investigation, thereby satisfying both constitutional and statutory safeguards.

Defendant asserts that the probable cause requirement was not fulfilled by evidence of the Commonwealth. When considered in totality, the circumstances clearly gave rise to a “fair probability” that like contraband or evidence of a crime would be found within defendant’s residence and justified issuance of the disputed warrant. The description of the items to be seized was included in the affidavit and was a part of the warrant. Where the actual photographs and attendant circumstances, including an explanation of the images, were before the judicial officer issuing the warrant, providing facts that substantially enhanced the measure of probable cause in support of the warrant, there was no constitutional or statutory taint to the affidavit, search warrant, or related search.

JUDGMENT:

The trial court’s judgment was affirmed.

Disclaimer:

These summaries are provided by the SRIS Law Group.  They represent the firm’s unofficial views of the Justices’ opinions.  The original opinions should be consulted for their authoritative content.

69ing, Dirty Talk, and Pornography – ROFL