Child Sex Dolls and Robots: More Than Just an Uncanny Valley

Abstract

Currently, there is a dual threat to children (and society) in the United States:— (1) the lack of explicit criminalization of the production, distribution, receipt, possession, use, or possession with intent of distribution of child sex dolls and robots; and (2)— the absence of clear guidelines, due to courts’ differing interpretation of the Prosecutorial Remedies and Other Tools to End the Exploitation of Children Today Act (PROTECT Act) of 2003, which could potentially be utilized to prohibit some of the aforementioned activities.

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December 2017 JOURNAL OF INTERNET LAW
3
Child Sex Dolls
and Robots: More
Than Just an
Uncanny Valley
By Dr. Marie-Helen Maras
and Dr. Lauren R. Shapiro
Currently, there is a dual threat to children
(and society) in the United States: (1) the lack of
explicit criminalization of the production, distribu-
tion, receipt, possession, use, or possession with intent
of distribution of child sex dolls and robots; and
(2) the absence of clear guidelines, due to courts’ dif-
fering interpretation of the Prosecutorial Remedies
and Other Tools to End the Exploitation of Children
Today Act (PROTECT Act) of 2003, which could
potentially be utilized to prohibit some of the afore-
mentioned activities.
CHILD SEX DOLLS AND ROBOTS
In the United States, explicit graphic, gratuitous,
and sometimes even violent sex has become common-
place between (a) characters in non-pornographic
films, commercials, television shows, and videogames,
and (b) personal avatars in communication for inter-
net sites and cellphones.9 Objectification of children,
adolescents, and adults is inherent in free-market
competition by mainstream music (including videos),
film, car, and clothing industries. Many “show young
women in highly sexual ways,” although Coca-Cola
infamously uses a young, in-shape “pool-boy” sought
after by a sister, brother, and mother, portraying these
models “as sex objects rather than unique human
beings”10 to sell their products and services.11 Unlike
Hollywood movies and television shows, the rest of
these visuals do not come with the parental guide of
Motion Picture Association of America (MPAA) rat-
ings and TV Parental Guidelines that warn of sexual
content, graphic nudity, and violence.12
The relaxed beliefs towards early exposure to
sexualized material also may be derived from the
successful promotion of pornography by the sex
industry, currently making multibillions of dollars
through films, services, and products.13 The advent
of pornography began simply, with hand drawings of
nudes alone or engaging in sexual acts that were sold
individually or in books. With the invention of still-
and movie-cameras, it progressed to graphic sexual
content in photographs and 2-dimensional films that
were available for viewing in theatres or for purchase
by mail or in stores. Currently, there are both 2- and
3-dimensional movies and interactive games available
for free (supported by advertisements or customers pay-
ing to remove them) or for purchase on the Internet.
Dr. Marie-Helen Maras is an Associate Professor at the
Department of Security, Fire, and Emergency Management at
John Jay College of Criminal Justice. She is also part of the faculty
of the MS program in Digital Forensics and Cybersecurity and
PhD program in Criminal Justice at John Jay College of Criminal
Justice. Dr. Lauren R. Shapiro is an Associate Professor at the
Department of Security, Fire, and Emergency Management at John
Jay College in New York.
Sexual abuse prevention campaigns teach children
that their bodies belong to them,1 yet they are exposed
to contradicting messages in our society, including
that children are possessions of their family2 and
disobedience to adults will be punished.3 Research
shows that 55 percent of boys and 70 percent of girls
are sexually abused by someone they know (i.e., fam-
ily, acquaintance).4 Hence, children whose “relative,
neighbor, family friend, teacher, coach, clergyman” is a
pedophile5 are unlikely to resolve these discrepant mes-
sages to prevent their own sexual abuse.6 Consequently,
they rely on society to have mechanisms in place to
prevent and detect sexual abuse (i.e., child protection
services, mandatory reporters) and corresponding laws
against child sexual abuse, child sexual exploitation,
and child pornography to protect them.7 The state
has a judicially recognized “interest in preventing the
exploitation and sexualization of children” (derived
from the parens patriae doctrine) and “to protect chil-
dren from premature sexual stimulation by adults for
the adults’ gratification.”8

JOURNAL OF INTERNET LAW December 2017
4
The sex industry also provides non-contact
services through live peep-shows, phone services
(including sexting), and websites that are designed to
allow customers to use their avatars for cybersex or to
talk to and/or watch a real person posing, engaging in
sexual activities, or self-stimulating sexually.14 New
technology also allows customers to receive stimula-
tion through a special device attached to their geni-
talia and controlled by the person on the screen that
mimics oral, vaginal or anal sex (e.g., cyberdildon-
ics).15 The sex industry also produces and sells objects
advertised to promote enhancement of adult sexual
pleasure, despite being regulated by state and federal
laws (e.g., commercial distribution).16 The sex toy
industry had its origin in creating simplistic devices that
simulate and stimulate genitalia (e.g., dildos, artificial
vaginas, vibrators) and fetish items that appeal to vari-
ous sexual desires (e.g., lashes, whips, feathers). Over
the past 20 years, it evolved to devise models that
either partially mimic humans (e.g., inflatable plastic
female dolls, rubber female torsos with breasts and
buttocks) or completely emulate humans and their
orifices (e.g., silicone sex dolls and artificial intel-
ligence sex robots).17
Adult sex dolls and robots have been developed
and are available on the market. They are “made of a
flesh-like, heat-retaining silicone with detailed facial
features and first-rate replications of female orifices.
The vagina, anus, and mouth are all designed to cre-
ate suction upon use.”18 Male sex dolls also are avail-
able, but have fewer appearance options than female
dolls.19 A buyer may custom-order sex dolls and
robots with specific preferences in terms of common
aspects, such as body type, hair color, skin tone, and
facial features, and additional features, such as spe-
cialized clitoris with hymen and “pressure-released
urination.”20
There also are sex robots that contain computer
software to enable automation in response to voice
and face, engage in conversation, and mimic “pro-
grammable personalities.”21 For example, one proto-
type adult sex robot, Roxxxy by True Companion,
was marketed as having different “programmable
personalities,” such as “Wild Wendy;” “S&M Susan;”
“Mature Martha;” “Frigid Farrah;” and “Young Yoko.”
The latter two are the most disconcerting. “Frigid
Farrah” has a setting in which she rejects all sexual
advances and thus encourages the user to rape her; the
marketing tagline of this personality is “if you touch
her ‘in a private area, more than likely, she will not be
to appreciative of your advance.’ ”22 Equally disturbing
is the “Young Yoko” setting, which is marketed with
the tagline “oh so young (barely 18) and waiting for
you to teach her.”23 The connotation is that the user
exerts control over the naïve robot to force it to learn
solely how to please the trainer sexually, completely
in contrast to her own sexual awakening as would be
found in human relationships. The harm to society of
these sex dolls and robots is their promotion of the
notions that women are “passive, ever-consenting sex
objects” and “consent is not a necessary part of sexual
interaction in cultures already struggling to teach that
‘no means no.’ ”24
Adult sex robots, such as the Real Doll
(Harmony) and Synthea Amatus (Samantha), and
True Companion’s Roxxxy, can move and speak.
These companies have created, are working on, and/or
are releasing adult sex robots that are life-like and of
the same materials as life-like dolls, with the addi-
tion of artificial intelligence and movement of the
dolls.25 Some “have moveable joints” and may have
motorized features, including moveable tongues and
toes, as well as “simulated respiration and heartbeats,
vocal reactions to genital penetration,” seemingly as
a means to induce the user to believe that the dolls
are enjoying the sexual activity.26 Adult sex dolls and
robots can perform a variety of sexual activities; one
robot known as Samantha purportedly can have
orgasms.27 Brothels in Japan, Austria and Germany
now offer clients sex with life-like adult dolls, where
the dolls can be dressed and positioned according to
the preferences of johns.28
Although life-like adult sex dolls have been in
existence for a while, what is relatively new are life-
like child sex dolls. Like their adult counterparts,
child sex dolls are realistic reproductions of young
(prepubescent) children in size and appearance with
anatomically correct genitals and anus, with all ori-
fices able to accommodate the length and width of
adult male genitalia. A known creator of such dolls
is Shin Takagi, a self-proclaimed pedophile, who
founded a company that sells them (Trottla) in Japan,
supposedly as an “alternative” to actual offending.29
The child sex dolls are designed to meet the various
desires, tastes and demands of customers. For exam-
ple, apart from custom design of the doll replicating
the requested ‘age’ and ‘sex’ of the child, customers
can also choose facial expressions, such as whether it

December 2017 JOURNAL OF INTERNET LAW
5
is happy, sad, angry, scared, etc.30 Moreover, although
not yet reported in the media, the likelihood is good
that the production of child sex robots capable of
moving, speaking, and performing sexual activities,
may be further along than adult robots due to their
smaller size and weight.31
Sex dolls and robots promote (the acceptance
of) non-consensual sex and rape, otherwise, set-
tings would not exist whereby the dolls and robots
express negative reactions when sexual advances
are made (e.g., Frigid Farrah setting on Roxxxy).
Sex dolls and robots can be used as a way to express
violent desires, independently or in conjunction
with sexual activity. One sex doll repairman indi-
cated that an owner had “ripped the leg off” the
female doll and “her calves, from below the knee,
had what looked almost like knife puncture wounds.
Hundreds of them.”32 Some of the dolls/robots were
destroyed in grotesque ways, such as “hacked to
pieces,” “jaw … behind her neck. Her hands ripped
off … left breast hanging by a thread of skin,” “cleav-
age between her buttocks was torn into a ragged
crevasse,” “her vagina and anus were a giant gaping
hole,” and “he put her feet behind her head and
reamed that doll … violently.”33
Sex dolls and robots are “specifically designed
for personal interactions that will involve human
emotions and feelings,” but these are one-way rela-
tionships.34 Current technology for these sex dolls
and robots does not include the capacity for even
mimicking human emotional distress in response to
aggression aimed at them. That is, when the user’s
violent actions result in visible tears of the vagina
or anus or in severing of a limb, these consequences
are not paired with obvious vocal signs of pain
and agony nor verbal cries for help. Hence, the
aggressor may become habituated to the effects of
applying sexual and physical harm on a nonconsen-
sual partner and escalate the attacks (as would be
expected in a rape-culture). Those who would argue
against societal harm from the expression of aggres-
sion against life-like dolls and robots need only
look at what happened in Austria at a technology
expo where Samantha was exhibited. Despite being
‘molested,’ such as it’s breasts and torso mounted by
multiple men to the point of breaking it’s fingers
and causing thousands of euros damage from ‘soil-
ing,’ when asked politely “How are you?” Samantha
responded, “Hi, I’m fine.”35
THE LEGAL LANDSCAPE:
MIND THE GAP
There are no US laws that explicitly prohibit
child sex dolls and robots. However, there are laws
that protect children by prohibiting child sexual abuse
(e.g., sexual activities with children) and child sexual
exploitation (e.g., use of a child for sex in exchange
for remuneration of some kind).36 Laws against child
pornography,37 which include “the visual, audio,
written, or other form of portrayal of sexual activity
of a … [minor] that is designed to sexually arouse a
viewer” also exist.38 In order to determine whether
child sex dolls and robots should be prohibited by
US law, one needs to understand the legal landscape
criminalizing child pornography, obscene materi-
als, and obscene virtual representations of children
engaging in sexually explicit conduct.
CAN A CHILD SEX DOLL AND ROBOT
BE CONSIDERED CHILD PORNOGRAPHY?
To address this question, it is important to deter-
mine the classification of child sex dolls and robots.
Under 18 U.S.C. § 2256(8), child pornography is
defined as
any visual depiction, including any photo-
graph, 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—(A) the production of such visual
depiction involves the use of a minor engaging
in sexually explicit conduct; (B) such visual
depiction is a digital image, computer image,
or computer-generated image that is, or is
indistinguishable from, that of a minor engag-
ing in sexually explicit conduct; or (C) such
visual depiction has been created, adapted, or
modified to appear that an identifiable minor
is engaging in sexually explicit conduct.
The production of child pornography causes pri-
mary harm to children. Here, the harm experienced
by the child is the direct result of child pornogra-
phy, such as the harm experienced from the sexual
exploitation and the emotional distress, physical and

JOURNAL OF INTERNET LAW December 2017
6
psychological harm, and other adverse consequences
experienced in the making of the child pornography.
In Osborne v. Ohio, the court held that “[t]he materi-
als produced by child pornographers permanently
record the victim’s abuse. The pornography’s exis-
tence causes the child victims continuing harm by
haunting the children in years to come.”39 The direct
harm caused to children in the original production
of the material, as well as the risk of further harm to
children (due to the revictimization from redistribut-
ing the material), are the primary reasons why child
pornography is considered illegal in United States.40
Due to the primary harm caused to children, the court
in New York v. Ferber concluded that child pornog-
raphy should be considered illegal on both state and
federal levels, and that the government could legally
intervene to protect children in this regard.41
Child sex dolls and robots are not consid-
ered as a form of child pornography because these
objects are not real children and cannot, by way of
extension, experience direct or continuing harm.
Nevertheless, child sex dolls and robots could be
classified as “virtual child pornography” as originally
defined by the Child Pornography Prevention Act
(CPPA) of 1996 as,
any visual depiction, including any photo-
graph, film, video, picture, or computer, or
computer-generated image or picture, whether
made or produced by electronic, mechanical,
or other means, of sexually explicit con-
duct, where … such visual depiction is, or
appears to be, of a minor engaging in sexually
explicit conduct … or … such visual depiction
is advertised, promoted, presented, described,
or distributed in such a manner that conveys
the impression that the material is or contains
a visual depiction of a minor engaging in sexu-
ally explicit conduct.
The phrases “appears to be” and “conveys the impres-
sion” enables the criminalization of content and
objects that do not involve real children.
Child sex dolls and robots are realistic virtual
representations of children, which may or may not
have been created with an image of a real child. As
such, these objects have anatomically correct parts
and orifices that could be used by pedophiles to insert
a penis, finger, tongue, or object in them to simulate
sexual activity, sexual assault, and sexual abuse as
listed under 18 U.S.C. § 2256(2)(A) as, “actual or
simulated—(i) sexual intercourse, including genital-
genital, oral-genital, anal-genital, or oral-anal,
whether between persons of the same or opposite
sex; (ii) bestiality; (iii) masturbation; (iv) sadistic
or masochistic abuse.” Even by themselves, these
life-like child sex dolls and robots are physiologically
identical to real children and thus, would meet the
legal definition of “sexual explicit conduct” under
18 U.S.C. § 2256(2)(A), which includes: “lascivious
exhibition of the genitals or pubic area of a child.”
As the Department of Justice noted in its “Citizen’s
Guide to U.S. Federal Law on Child Pornography:”
“the legal definition of sexually explicit conduct does
not require that an image depict a child engaging
in sexual activity. A picture of a naked child may
constitute illegal child pornography if it is sufficiently
sexually suggestive.”42 For these reasons, it may be
concluded that child sex dolls and robots are clearly a
form of virtual child pornography.
In Ashcroft v. Free Speech Coalition,43 the majority
opinion countered the government’s points, which
sought to justify the prohibition of virtual child por-
nography, in the following ways.44 First, it denied any
causal connection between virtual child pornography
and future commission of pedophilic acts, thereby
also negating the “indirect harm” claim. Second, it
disclaimed the notion that virtual child pornography
spurred actual child pornography and sexual exploita-
tion. For these reasons, the court in Ashcroft struck
down CPPA as unconstitutional concluding that only
child pornography that depicted a real child could be
prohibited by law.45
The next issue to consider is whether child sex
dolls and robots as virtual child pornography cause
harm to children and society, as was suggested by the
government in Ashcroft v. Free Speech Coalition. In
Ashcroft, the court rejected the government’s conten-
tion that “virtual child pornography whets the appe-
tites of pedophiles and encourages them to engage in
illegal conduct”46 and concluded that “the govern-
ment ‘cannot constitutionally premise legislation
on the desirability of controlling a person’s private
thoughts.’ ”47 Evidence from social science research is
introduced next to address whether the government’s
original assertions of harm are accurate in 2017.
Research has shown that the distinction between
contact and non-contact child sex offenders is

December 2017 JOURNAL OF INTERNET LAW
7
tenuous at best;48 the contact sex offense rates of
those viewing child pornography online varied.49 It
would be unethical to determine whether a causal
connection between child pornography or virtual
child pornography and child sexual abuse exists
through empirical research.50 That is, investigators
would not risk potential harm to children by forcing
pedophiles to view content and then gather evidence
of child sexual abuse. However, empirical data has
shown a positive correlation between pornography
and sexual offenses against children, such as child
molestation,51 and between child pornography and
child molestation.52 For example, findings from one
study revealed that approximately half (43 out of
100) of the offenders charged with child pornography,
also were charged with a child sex offense.53 A posi-
tive correlation between crimes committed against
children and child pornography has been reported by
state-based Internet Crimes Against Children task
forces in Pennsylvania and Texas.54 Overall, research-
ers, the government, the judiciary,55 and Congress
recognize the nexus between child pornography and
sexual offenses committed against children.56
Studies on child sex offenders have shown that
child pornography is a strong diagnostic indicator of
pedophilia.57 The consumption of child and virtual
child pornography does not prevent pedophiles from
future offending. Instead, viewing child pornography
(actual and virtual) is considered to be a progressive
addiction that serves as a gateway to child sexual
abuse. Specifically, passive viewing of child pornogra-
phy often becomes insufficient for the perpetrator as
he or she becomes desensitized to it.58 The perpetra-
tor escalates to the next level by masturbating to the
image (i.e., actively sexually self-stimulating), seek-
ing out more extreme versions of child pornography,
and/or by acting out impulses (e.g., sexually abusing
a child) in order to receive the same (original) level
of stimulation and gratification.59 Sullivan and Beech
suggest that while not all child sex offenders who mas-
turbate to child pornography sexually abuse children,
this activity increases their risk of doing so because
of the pairing of their fantasy (i.e., sexual abuse of a
child) with masturbation and subsequent orgasm (i.e.,
reward for this act), which ultimately conditions and
reinforces their behavior.60 For these reasons, the use
of even virtual child pornography increases the risk of
harm to real children.61 As the court held in Turner
Broadcasting System Inc. v. FCC, “[a] fundamental
principle of legislation is that Congress is under no
obligation to wait until the entire harm occurs but
may act to prevent it.”62
Similar arguments can be made for the use of
child sex dolls and robots. Recent arrests and convic-
tions of pedophiles in the United Kingdom for import-
ing child sex dolls revealed that the perpetrators also
possessed scores of child pornography in digital format
in their homes.63 These cases of intercepted child
sex dolls evidence the offenders’ desensitization and
overwhelming desire that escalated them from being
viewers of child pornography (an illicit act in and
of itself) to being engagers of sex acts with child sex
dolls. Accordingly, in these cases, child pornography
did “whet the appetite of the perpetrators” as their
“thoughts” (fantasies about sex acts with children)
became “behaviors” (through buying and importing
the child sex doll to perform sex acts with it).
The thrill to the pedophiles of physical recipients
of their lustful desires, the child sex dolls in these
cases, is consistent with recent evidence showing
that the effect of a robot was considered to be “more
persuasive and engaging when physically present
than onscreen.”64 Moreover, the offenders’ pairing
of “thought” (fantasy about sex act with child)
with “inappropriate action” (sex act with child doll
or robot) creates “muscle memory,” whereby their
body will remember the act and stimuli associated
with it. With each repetition, the pedophile’s needs
increase, as does his desires for more extreme versions
to achieve the same level of gratification. In sum-
mary, this evidence supports the notion that virtual
child pornography in the form of child sex dolls and
robots does incite lust in pedophiles and propels them
towards future offenses with real children.
CAN CHILD SEX DOLLS AND ROBOTS BE
CONSIDERED OBSCENE MATERIAL?
This question is best addressed by examining
what are considered obscene materials to deter-
mine whether child sex dolls and robots fit in
this category. To be obscene, the object must be
“patently offensive representations or descriptions
of ultimate sexual acts, normal or perverted, actual
or simulated,”65 which erodes moral standards and
“has a tendency to injure the community as a whole,
to endanger … public safety, or to jeopardize … the

JOURNAL OF INTERNET LAW December 2017
8
state’s right to maintain a decent society.”66 For these
reasons, the court in Roth v. United States67 concluded
that “obscenity is not within the area of constitu-
tionally protected speech” and undeserving of First
Amendment protection.68
Three countries—United Kingdom, Australia,
and New Zealand—already have determined that
child sex dolls are obscene and by way of extension,
child sex robots also would be considered obscene
in these countries.69 Another Western country—
Canada—is in the process of evaluating them70 and
the United States should follow suit. Originally, the
test to determine obscenity applied in Roth v. United
States was: “[w]hether to the average person, applying
contemporary community standards, the dominant
theme of the material as a whole, appeals to the
prurient interest.”71 To appeal to a prurient interest,
the “material [must] hav[e] a tendency to excite lust-
ful thoughts.”72 However, the obscenity test used in
Roth was subsequently replaced by the Miller test. The
plurality of the court in Miller v. California73 estab-
lished three criteria to determine whether material
is obscene. According to Miller, the material must:74
(1) appeal to prurient interest; (2) be considered
patently offensive according community standards; and
(3) lack scientific, literary, artistic or political value.75
Thus, in order for child sex dolls and robots to be
considered obscene in the United States, these objects
must satisfy the three conditions of the Miller test.
The first condition to satisfy is, do they appeal to
prurient interest? To address this question, two psycho-
logical theories that form the basis of clinical therapy
with pedophiles will explain how child sex dolls and
robots would “excite lustful thoughts.” Both theories
address bi-directional causal links between thoughts
and actions. An information processing model76
describes the cognitive processes involved when
pedophiles engage in sexual activities with child sex
dolls and robots. Child sexual abuse and/or exploita-
tion schema (i.e., internal representations of how to
use a child for one’s own gratification) are formed
from various sources,77 including media exposure
to child or virtual child pornography and personal
or others’ experiences of sexual abuse/exploitation
of a child. Schemas are modified with subsequent
exposure and experiences,78 creating a complex con-
ceptual framework of how to select, seduce (groom),
and sexually abuse/exploit children, and, likely, how
to avoid detection. Thus, when the pedophile is
in the presence of a child, whether a real one or a
close approximation (i.e., child sex doll or robot),
the schema will be activated and, through a process
known as spreading activation, all related thoughts
and behaviors also will be triggered.79 Specifically, a
single thought (e.g., this girl-doll is attractive) sparks
other, semantically (categorically) similar thoughts
in a domino-like process (e.g., I want to undress
her, I want to touch her, etc.), and when primed
with a specific related concept (e.g., sexy, arousing),
this process happens rapidly. Research with non-
pedophile college aged adults demonstrated the
strength of ‘barely legal models’ exposure had on
response latencies: they responded most rapidly for
the pairing of an underage female model photograph
with the word “arousing,” “sexy,” and “erotic.”80
Pedophiles would predictably have intricate schemas
for offending and a cognitive association network that
could be easily primed, allowing them to ruminate on
other ideas involving harm to children.81
Social learning theory82 can also explain how pru-
rient interests would form and be maintained through
the use of child sex dolls and robots. In Ashcroft, the
government’s warnings that virtual child pornography
would lead to future sexual abuse or exploitation of
minors was rejected by the court. However, psycholo-
gists applying the four tenets of this theory to explain
pedophilia thoughts and actions would support the
government’s position. Consistent with the first
tenet, pedophiles learn sexual abuse and exploitation
of children through watching and exchanging child
porn; real and virtual social interactions with other
pedophiles who have, share, and promote the same
or similar values, attitudes, and beliefs; and from
performing these acts on children (sometimes for the
purpose of producing child pornography), and theo-
retically now on child sex dolls and robots.
The second tenet of social learning theory would
involve pedophiles’ use of their support systems to
help them neutralize the shame and minimize nega-
tive emotions that mainstream society associates with
child sexual abuse and exploitation.83 Case in point,
it was a pedophile, Shin Takagi, who developed and
encouraged other pedophiles to use his child sex
dolls.84 Pedophiles are able to engage purposefully in
sexually deviant behaviors through cognitive distor-
tions that allow them to “deny, justify, minimize, and
rationalize … [their] actions.”85 Even when the victim
is crying and bleeding from the sexual assault, the

December 2017 JOURNAL OF INTERNET LAW
9
pedophile is oblivious to the child’s pain and does not
experience the normally associated negative feelings
of shame, guilt, and anxiety.86 That is, the pedophile
is in denial of the emotional and physical damage
suffered by the victim87 and interpret the child’s
behaviors as initiating sexual contact or expressing
pleasure from it.88 These cognitive distortions provide
rationalizations, reduce the pedophile’s guilt associ-
ated with the desire and assault, and minimalize the
fear of being caught, allowing the cycle of abuse to
continue.89
In accordance with the third tenet of social learn-
ing theory, pedophiles receive two types of rewards
that increase the performance of abuse and exploita-
tion of children.90 One is praise from other pedophiles
when they share pictures/films and/or describe their
sexual abuse and exploitation of children, therein
contributing to the “normalizing” of these actions and
thoughts.91 Another is from the physical arousal and
pleasure obtained from watching and performing the
sexual acts on children. For example, child sex dolls
and robots that have recordings of pleasure sounds,
when combined with the pedophile’s orgasm through
sexual activity with them will positively reinforce the
message that children enjoy sexual activities with
adults. Child sex dolls are (and child sex robots will
be, if not already) created in such a way that perpetra-
tors will believe that the sex doll (or robot) is a real
child.
The ultimate goal of manufacturers is to make
the sex dolls and robots look and feel as realistic as
possible (this is what the creators of adult sex dolls
and robots have claimed; e.g., creator of Samantha).
Child sex dolls and robots have realistic, soft skin,
inviting the pedophile to touch, caress, hold, and
otherwise provide pleasant tactile experiences for
them. Therein lays the problem. “Human beings
have strong intrinsic tendencies towards building
basic communicative functions and attachment rela-
tionships through touch.”92 It is through touch that
people “organize and direct … social experience” and
these tactile interactions provide people with “com-
plex, relational feelings of intimacy.”93 Hence, con-
trary to the notion that the use of child sex dolls and
robots will have a decreasing effect on pedophilic
impulses, desires, and urges, these anthropomorphic
objects will provide pedophiles with ways to engage
in complex sex acts that in and of themselves will
be reinforcing. “The primacy of bodily interaction,
with many channels of tactile or proprioceptive
feedback the robot may give and receive”94 would
make it extremely desirable and highly addictive for
pedophiles.
Recent research has shown the implications of
touch between humans and robots, indicating that
“even basic forms of touching, whether by or of a
robot, may arouse a person.”95 In a recently presented
study, 10 adults equipped with sensors were asked to
point or touch 13 accessible (e.g., hands, head) or
non-accessible (e.g., genitals, buttocks) body parts
on a 23-inch, artificially looking, NAO robot. These
non-offending adults were aroused and hesitated lon-
ger in response to the request to touch ‘intimate’ parts
of the robot as compared to non-intimate parts.96
It could be deduced that the arousal of pedophiles
touching or otherwise interacting sexually with child
sex robots would be the same or greater.
Even more alarming is when child sex dolls and
robots have a ‘voice,’ whether pre-recorded or record-
able, or in the case of AIs, programmed, to ‘stroke the
ego’ of the user. Like their adult counterparts, they
would provide positive reinforcement by telling the
user how much they enjoy any and all acts performed
on them, including violence and forced sex with one
or multiple adults. For the pedophile who already is
convinced that the child enjoys sexual contact,97 the
doll or robot is confirming this belief through verbal
statements, such as “I like it when you touch me
there.” However, even the use of child sex dolls and
robots without recordings can be harmful as children
are not physically or cognitively able to resist sexual
advances by adults. The child sex dolls and robots
do not provide distress cues, a firm “no,” or attempts
to escape, all of which could be interpreted by pedo-
philes as consent.98
Psychiatrists are concerned that pedophiles, who
have several social, cognitive, and emotional deficits
(i.e., inability to recognize distress or to empathize
with victims),99 would not be able to discern sexual
contact as part of the fantasy with child sex dolls and
robots from the reality with actual children.100 This
is because it is the act itself, not the ‘object,’ that
reinforces the fantasy for the pedophile. Moreover,
the positive reinforcement of programmed child sex
dolls and robots to have an ‘orgasm’ (as adult ones are
now capable of doing) may solidify for the pedophile
their current misconception that children like and
desire sexual relations.101 Therefore, child sex dolls

JOURNAL OF INTERNET LAW December 2017
10
and robots’ ability to incite lustful thoughts combined
with the pedophiles’ cognitive distortions helps them
to maintain illicit desires through reward as part of
fantasy engagement and sexual release.
There is no question that both the passivity of
the silent realistic looking child sex doll and robot
and the active acceptance of the assault by the
recorded or programmable ones indicating pleasure
increase lust in the pedophile. Specifically, the ‘silent’
child sex doll or robot fails to provide the needed
socio-emotional and cognitive feedback that would
break the impoverished empathy/cognitive distor-
tion cycle of the pedophile and inhibit its use.102 The
positive vocalizations (and physical reactions, such
as orgasm) of the child sex doll or robot confirms for
the pedophile that his act of rape is enjoyable for the
“child” and encourages future abuse. Hence, both of
these types of child sex dolls and robots serve the pur-
pose of appealing to prurient interests. This is particu-
larly problematic given that real child orifices cannot
accommodate the adult male genitalia the way the
child sex dolls/robots do, ultimately leading to chok-
ing, broken teeth, and tears in the throat; bleeding
and tears in perianal region, vagina, and anus; and
damage to internal organs (when the vagina and anus
fails to accommodate the adult penis).103
The fourth and final tenet of social learning
theory indicates that pedophiles learn their abusive/
exploitive thoughts and behaviors through imitation
of modeled behaviors of the adult abusers in child
and virtual child pornography. The frequency of these
behaviors will be modulated by the pedophile’s per-
ception of past and future (anticipated) rewards given
to the pedophilic model in the child/virtual child
pornography photos and film (i.e., through vicarious
reinforcement, such as pleasure from the child abuse/
exploitation).104 Moreover, pedophiles who watch
virtual child models display arousal and pleasure
derived from their sexual activities with adults will
be further encouraged to emulate the abuse/exploita-
tion. In this way, these false reactions feed into the
pedophile’s current misperceptions of their own child
victim’s emotional responses to his/her abuse/exploi-
tation; thus, cognitive distortions allow pedophiles to
perceive even real child models as exhibiting pleasure
regardless of the emotion actually portrayed (i.e., fear,
distress). Additional support for pedophile’s disinhibi-
tion to child sexual abuse and exploitation is evident
in research examining men’s reactions to violent
pornography (e.g., woman aroused and enjoying
being raped), which demonstrated exposure encour-
aged them to emulate these behaviors.105 Repeated
exposure to depicted violent sexual activity also pro-
duced profound effects in which viewer’s perceived
distress towards the actresses was reduced, as was their
judgments of harm to women from intimate partner
violence.106 In these ways, child and virtual child por-
nography provides incentives through observation to
imitate the portrayed child abuse/exploitative behav-
iors. By extension, imitation of abuse/exploitation of
children will be endorsed through the use of child sex
dolls and robots.
The second condition to satisfy is, are they consid-
ered patently offensive according to community standards?
Patently offensive describes materials that are clearly
or evidently offensive to the public who views them.
For example, child pornography, such as sexually
explicit material with actual minors or sexual inter-
action between adults and minors, was determined
by a group of college students (35 men, 125 women)
to be neither socially acceptable nor legitimate.107
Additionally, research shows that society would per-
ceive sex with a child sex doll or robot to be sex
rather than masturbation. According to a study of 198
adults’ beliefs about sex robots, although 71 percent
agreed that “no law prevents sex with a robot,” only
22 percent agreed that “minors could legally have sex
with robots” and only 30 percent agreed that “sex
with a sex robot is not really sex and does not count as
sex.”108 Similarly, although 62 percent of these adults
agreed that “one cannot rape a sex robot,” only 42
percent agreed “any action (e.g., hitting) is allowed
with a sex robot.” These results indicate that society
does not believe sex robots were simply objects, oth-
erwise they would not be opposing actions that could
potentially result in physical damage.109
In the last few years, dolls resembling children
have been created to the extent that some are almost
indistinguishable from real ones. For example, the
reborn doll is so realistic a police officer in Keene,
New Hampshire, broke the window of a vehicle after
he saw what appeared to him to be an infant in a
locked car.110 As noted earlier in this article, child
sex dolls and robots are similarly realistic and empiri-
cal research supports the notion that society would
likely believe that these “lifelike dolls, unlike vibra-
tors, are simulated humans” and “all of the stimuli
are telling you it’s human.”111 In two related studies

December 2017 JOURNAL OF INTERNET LAW
11
(Study 1: N = 57 men, 43 women, M age = 33.25,
Range 20-61 years; Study 2: N = 114 men, 84 women,
M age = 34.24, Range 18-63 years), adults were asked
to indicate the appropriateness of various interactions
with sex robots.112 Men had more lenient beliefs about
the appropriate use of sex robots than did women
for many of the suggestions (e.g., for sex offenders; for
group sex such as mixed human-robot group sex; for
pornographic movies; to engage in unusual sex prac-
tice such as rough sex or sadistic behavior). However,
when asked about “appropriate physical forms for sex
robots … child forms are opposed strongly by both.”113
The idea that child sex dolls and robots would be
used for adults’ sexual gratification is a difficult iso-
morphism to suppress. Therefore, the fact that they
look like human children, combined with the primary
purpose of their orifices being to accommodate an
adult penis, are what makes child sex dolls and robots
patently offensive.
The third condition to satisfy is, do they lack
scientific, literary, artistic or political value? There is no
scientific value in child sex dolls and robots. Naïve
theories have been proposed that pedophiles’ use of
child sex dolls and robots may substitute for their
desire to attack real children. Similarly, the chair of a
Welsh charity, the Specialist Treatment Organization
for the Prevention of Sexual Offending (StopSO),
which focuses on the prevention of sexual offending
through therapy, stated to the media that child sex
dolls could be used in a controlled environment to
deter pedophiles from offending against children in
real life.114 However, there is no evidence to support
“therapeutic” use of child sex dolls and robots as a
means for decreasing pedophiles’ desire to use real
children to satisfy their own sexual desires. Instead,
the psychiatric community is concerned that pedo-
philes’ use of child sex dolls and robots will contribute
to their interpreting sex with children as acceptable–
rather than as child sexual abuse and/or child sexual
exploitation. Jon Brown, who is the head of develop-
ment at the National Society for the Prevention of
Cruelty to Children (NSPCC), stated “There is no
evidence to support the idea that the use of so-called
child sex dolls helps prevent potential abusers from
committing contact offences against real children.”115
The argument that giving perpetrators of child
sexual abuse access to child sex dolls and robots as
a way for them to express their impulses and desires
and prevent them from doing this with real children
is fundamentally flawed. The use of these child sex
dolls and robots in treatment of rapists and sexual
abusers would normalize sexual assault and abuse.
According to Dr. Tucker, “it would be dangerous for
a pedophile to use a young-looking doll” because
it would “rehearse offending behavior … reinforcing
his fantasies with orgasm.”116 Moreover, it would be
impossible to conduct scientific research to determine
the use of child sex dolls and robots as part of therapy
with pedophiles. This is because patients will be able
to purchase (or produce on a 3D printer) and use
them at home, invalidating the data from their use
in therapy.
The use of realistic child sex dolls and robots in
treatment is anathema to cognitive-behavioral ther-
apy which seeks to remove undesirable thoughts and
behavior (i.e., sexual contact with children for one’s
own gratification). For example, therapists would
attempt to desensitize patients from having pleasure
responses associated with thoughts and behaviors of
harming children. Clinicians also would reinforce
societal beliefs that desire for and sex with children
is wrong and harmful. In contrast, encouraging pedo-
philes to have sexual activity with realistic looking
child sex dolls and robots would increase their inap-
propriate thoughts and behaviors towards children
and reconfirm their beliefs that child sexual abuse and
exploitation is ‘normal’ and acceptable. Therapists, in
contrast, work towards dispelling the cognitive distor-
tions pedophiles use to justify their behavior, which
downplays the seriousness of their conduct and acts
to minimize the impact of their behavior.117
The reality is most treatment for pedophilic
disorder is court-ordered and as such has extremely
low success.118 The majority of pedophiles are never
caught and rarely go into treatment voluntarily, so
they offend repeatedly. Even when arrested and con-
victed, their reoffending rates of “10–50 percent” are
likely under representing those who are still offend-
ing.119 That is, pedophiles are able to keep offending
and have no need to change their abuse because it is
still satisfying for them. Instead, they have increased
their ability to avoid being caught, most likely by
using nonverbal victims as evidenced by the increase
in sexual abuse of infants and toddlers.120
Accordingly, the view that creating an anthropo-
morphic child sex doll and robot to enable offenders
to act on their impulses to rape and abuse children as
therapeutic is nonsensical and irrational. Child sex

JOURNAL OF INTERNET LAW December 2017
12
dolls and robots normalize sexual assault, violence,
and domination, they do not supplant it or inhibit it.
These robots and dolls are made in the images
of children, thus dehumanizing them by reducing
them to objects. Pedophiles already dehumanize
their child victims as a means of rationalizing their
abuse and exploitation.121 Dehumanization enables
individuals to view others as undeserving of moral
and ethical considerations and it prevents individuals
from empathizing with those it views as subhuman
or unhuman.122 Child sex dolls and robots are the
utmost embodiment of the reduction of children to
a sexual object for the gratification and pleasure of
their owner/user.
A similar line of argument comes from feminist
critique of pornography; in general, it is the “eroti-
cization of inequality.”123 Men and women can (and
should) be equal in consenting sexual activity. In
contrast, “child pornography, actual or virtual, cannot
depict children as equal partners in sexual activity
with adults, nor can it establish a relation of equality
between the adult viewer and the viewed child.”124 In
fact, science supports the notion of children’s cogni-
tive, social, and physical immaturity that makes them
unequal to adults and the need for society to protect
them against harm.125 Hence, even virtual child
pornography, which contains the “sexualization” of
the adult-child relationship is harmful,126 because
“sexualizing children for adult viewers is necessarily
sexualizing inequality.”127 It “depicts an adult’s exploi-
tation of his power over the child” and “the child is
incapable of consenting to the activity depicted.”128
But even worse is the use of realistic child sex dolls
and robots because they extend the adult-child sexual
relationship by making it feel less like fantasy and
more like reality.
Empirical research also would negate the benefits
of pedophiles’ use of child sex dolls and robots to pre-
vent future offending. First, exposure to pornography
increases the watchers’ desire to have sex.129 That is,
the visual and auditory stimulation of adults engag-
ing in sexual activity does not decrease or satisfy the
watchers’ sexual interest. Additionally, exposure to
violent pornography increases the watchers’ desire
to engage in violent sexual activities as they inter-
pret the actress’ reactions in the film as enjoying the
violent actions.130 Studies on sex offenders further
reveal that pornography predisposes, legitimizes, and
normalizes men to abuse, develops and reinforces
faulty belief systems of abuse and victims of abuse,
and reduces inhibitions about committing abuse.131
Second, the thrill of novelty decreases over time
with repeated engagement. A biological explanation
for this phenomenon is that watching pornography
decreases dopamine in the synapses, which requires
higher levels in order to provide the same response.
Pedophiles who watched child pornography indicated
that they needed more severe material with each
viewing.132 Similarly, the assault, rape, and sexual
abuse of the child sex doll or robot will no longer
be satisfying. This is known as the Coolidge effect133
and refers to a phenomenon in mammals, particularly
males, such that arousal and desire for intimacy with
the same partner declines over time. However, inter-
est is renewed when a new partner is introduced.134
In other words, the use of a particular child sex doll
or robot will eventually not be able to satisfy the
pedophile’s perverse sexual desires. They will need to
change dolls or robots to keep up their fantasy and
satisfaction, but the cost of the dolls (e.g., $5000-
50,000) is prohibitive.135 Therefore, when given the
option of using a child sex doll/robot or real child,
pedophiles will choose the latter as the child does not
require purchase and, being new, becomes the optimal
solution to their boredom with the child sex doll
and/or robot.
In contrast to the court’s conclusion in Ashcroft,
the psychology field would conclude that pedophile’s
use of child and virtual child pornography and child
sex dolls and robots appeal to prurient interest, are
patently offensive, and lack scientific value. The pedo-
philes continue to desire and require more child and
virtual child pornography and any approximations,
such as child sex dolls and robots. The court indi-
cated: “If virtual images were identical to illegal child
pornography, the illegal images would be driven from
the market by the indistinguishable substitutes. Few
pornographers would risk prosecution by abusing real
children if fictional, computerized images would suf-
fice.”136 This notion, that the nonreal child formats
(whether virtual child or dolls/robots) do not sate the
pedophiles’ desires, endorse the need for legislation to
limit all avenues that promote abuse and exploitation
of children.
A barrier to the use of the Miller test for pros-
ecutions for visual depictions of sexual explicit
activities of minors deemed obscene is that it does
not criminalize mere possession of these depictions

December 2017 JOURNAL OF INTERNET LAW
13
just the distribution, transfer, and receipt of it. The
reason why possession was not criminally prohibited
was not the result of the Miller test, but the ruling
in Stanley v. Georgia, which declared that the pos-
session of obscene material in the home cannot
be prohibited.137 In justifying the prohibition in
criminalizing possession of obscene material in the
home, the court argued “privacy of one’s own home”
outweighed government interest in “protecting the
individual’s mind from the effects of obscenity.”138
Mere possession of obscene materials was, thus, not
proscribed—with the exception of child pornography
(that involves real children).139 The possession, as
well as the receipt, distribution and production, of
obscene virtual representations of children engaging
in sexually explicit conduct is prohibited under the
PROTECT Act of 2003. The question that follows is:
Are child sex dolls and robots similarly proscribed
under this Act?
CAN CHILD SEX DOLLS AND ROBOTS
BE CONSIDERED OBSCENE VIRTUAL
REPRESENTATIONS OF CHILDREN
ENGAGING IN SEXUALLY EXPLICIT
CONDUCT UNDER THE PROTECT ACT?
The Congressional response to the decision in
Ashcroft v. Free Speech Coalition was the drafting
and passage of the PROTECT Act of 2003. This
Act amended the definition of “child pornography”
in 18 U.S.C. § 2256(8) to include “a digital image,
computer image, or computer-generated image that
is, or is indistinguishable from, that of a minor engag-
ing in sexually explicit conduct.”140 The requirement
that the prosecution show that an actual child was
used in the production of virtual child pornography
was relaxed by the court after the passage of the
PROTECT Act of 2003.141
The PROTECT Act also created a new obscen-
ity offense under 18 U.S.C. § 1466A, the obscene
virtual representations of children engaging in sexu-
ally explicit conduct. Particularly, Section 504 of the
Act amends 18 U.S.C. § 1466A(a) by criminalizing
the pandering (i.e., production, distribution, receipt,
or possession with intent of distribution) of obscene
visual depictions of children engaging in sexually
explicit conduct. Particularly, this section of the Act
is violated by
any person who … knowingly produces, dis-
tributes, receives, or possesses with intent
to distribute, a visual depiction of any kind,
including a drawing, cartoon, sculpture, or
painting, that—(1)(A) depicts a minor engag-
ing in sexually explicit conduct; and (B) is
obscene; or (2)(A) 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 oppo-
site sex; and (B) lacks serious literary, artistic,
political, or scientific value; or attempts or
conspires to do so.142
This section includes a scienter requirement (i.e., a
person knowingly engages in the illicit act) and crimi-
nalizes the pandering of any form of visual depiction
of a minor engaging in sexually explicit activities
considered obscene under the Miller test, as well as
the pandering of any form of visual depiction “that
is, or appears to be, of a minor engaging in” sexually
explicit activity that does not meet the Miller test.
Section 504 of the Act also amends 18 U.S.C.
§ 1466A(b) by criminalizing the possession of obscene
visual depictions of children engaging in sexually
explicit conduct. Specifically, this section of the Act
is violated by
Any person who … knowingly possesses a
visual depiction of any kind, including a draw-
ing, cartoon, sculpture, or painting, that—
(1)(A) depicts a minor engaging in sexu-
ally explicit conduct; and (B) is obscene; or
(2)(A) depicts an image that is, or appears to
be, of a minor engaging in graphic bestiality,
sadistic or masochistic abuse, or sexual inter-
course, including genital-genital, oral-genital,
anal-genital, or oral-anal, whether between
persons of the same or opposite sex; and
(B) lacks serious literary, artistic, political, or
scientific value; or attempts or conspires to
do so.143
This section also includes a scienter requirement
and criminalizes the possession of any form of visual
depiction of a minor engaging in sexually explicit
activity considered obscene under the Miller test, as

JOURNAL OF INTERNET LAW December 2017
14
well as the knowing possession of any form of visual
depiction “that is, or appears to be, of a minor engag-
ing in” sexually explicit activity that does not meet
the Miller test.
In United States v. Whorley,144 the defendant was
charged and convicted pursuant to the PROTECT
Act for knowingly receiving and possessing obscene
materials—cartoons, particularly Japanese anima-
tion (i.e., anime), which depicted minors engaging in
sexually explicit conduct. In United States v. Kutzner,
the defendant, Steven Kutzner, was charged with the
possession of hundreds of images of virtual child
pornography—depicting child cartoon characters,
some of which were the children of the popular US
television cartoon series “the Simpsons” (namely,
the children of the Simpson family, Lisa, Bart, and
Maggie).145 He pled guilty to possession of obscene
materials and received 15 months’ imprisonment.146
In McFadden v. Alabama, the court ruled that
collages and montages that included nude images
of children alongside adult genitals were obscene.147
Likewise, in Hotaling v. United States,148 the court held
that the mere possession of morphed pornographic
images of minors was proscribed, even when no real
children engaged in the sexual activities depicted in
the image. In this case, images were created whereby
the heads of children were digitally transposed onto
images of women’s bodies engaging in sexual activi-
ties. Given the court’s position on morphing, the cre-
ation of child sex dolls in the image of children based
on a child’s photograph would be prohibited by law.
The technology to create a sex doll based on a pho-
tograph of a person has been available since 1902.149
Currently, buyers are able to send pictures (i.e., actual
images of adults and children) to the manufacturer
and request that an adult sex doll be created in the
image, as well as a child sex doll in the image and
stature of a child.150 With respect to the latter, Shin
Takagi’s company, Trottla, is capable of creating such
custom-made child sex dolls.151
The courts in United States v. Ryan152 and United
States v. Mees153 upheld the constitutionality of the
sections of U.S.C. § 1466A that criminalized the
possession of obscene materials that did not involve
real children. Courts have varied, however, in their
interpretation of the constitutionality of 18 U.S.C.
§ 1466A(a)(2) and 18 U.S.C. § 1466A(b)(2). In United
States v. Handley,154 customs officials intercepted a
package that contained obscene materials, including
Japanese comics (i.e., manga), which depicted minors
engaging in sexually explicit activities among other
obscene drawings and cartoons (e.g., some depicted
bestiality). The court in Handley held that visual
depictions of minors engaging in sexually explicit
activity could be proscribed only if they are obscene
and involve real minors.155 The Handley court noted
that these conditions are not included in 18 U.S.C.
§ 1466A(a)(2) and 18 U.S.C. § 1466A(b)(2) and as
such, these subsections were viewed as unconstitu-
tional. While the Handley court ruled these sections
of 18 U.S.C. § 1466A were overbroad, a later court
refused to enforce this ruling. Specifically, in United
States v. Dean,156 the court upheld the defendant’s
conviction pursuant to 18 U.S.C. § 1466A(b)(2)
and did not find this subsection of the law over-
broad. Given the divergence of the opinions of the
courts regarding the constitutionality of 18 U.S.C.
§ 1466A(a)(2) and 18 U.S.C. § 1466A(b)(2), there
is a glaring lacuna in existing legislation and case law
that could be used to prosecute those who pander and
possess child sex dolls and robots. Consequently, it is
unclear whether the pandering and possession of child
sex dolls and robots, apart from those created from the
images of real children, would be prohibited by US law.
The United States is by no means unique; the
same gap in law exists in the United Kingdom. In
fact, the possession of child sex dolls, and, by way
of extension, child sex robots, are not considered
illegal according to UK law. The perpetrators of
recent cases involving child sex dolls in the United
Kingdom have been charged with the importation
of obscene materials. In the United Kingdom, the
importation of indecent or obscene articles are pro-
hibited by the Customs Consolidation Act of 1876.
Since March 2016, at least 123 child sex dolls being
sent from China and Hong Kong have been seized
by UK Border Force agents.157 One of these sex dolls
belonged to Andrew Dobson, who was arrested and
received two years and eight months imprisonment
for importing “an indecent or obscene article,” a
child sex doll resembling a four-year-old girl, from
Hong Kong.158 Another child sex doll belonged to
Dean Hall, who was sentenced to a 12-month sus-
pended prison sentence, required to register as a sex
offender for 10 years, and given a 10-year sexual harm
prevention order, along with community service and
mandatory rehabilitation.159 Andrew Larkins also
attempted to import a child sex doll; for his crime,

December 2017 JOURNAL OF INTERNET LAW
15
he was sentenced to a 24-month suspended prison
sentence, given a 10-year sexual harm prevention
order, and was required to register as a sex offender for
10 years.160 Likewise, Simon Glerum was found guilty
of importing a “an indecent or obscene article”161 and
received a suspended 12-month prison sentence and
a five-year sexual harm prevention order, and was
required to complete 20 days in rehabilitation and
complete a sex offender treatment program.162
In all of the above-mentioned cases, the child
sex dolls were intercepted by authorities before they
arrived to the homes of those who purchased them.
At least when the child sex doll or robot arrives
through the mail, the government could be alerted to
the potential danger, especially if delivered to a regis-
tered sex offender. However, if the child sex dolls fail
to be intercepted by authorities, criminals may evade
prosecution for the possession of these dolls given the
absence of existing legislation that can explicitly pro-
scribe these items and the lack of clarity on whether
existing laws could be used to criminalize these items.
What is more, once this technology can be produced
at home (with, e.g., a 3D printer, which is already
capable of making sex toys), the government will
have lost most of its ability to protect children. An
argument that could be made is that the child sex
dolls and robots had to be purchased for a perpetra-
tor to have them in his or her possession. However,
this only encourages perpetrators to seek alternative
avenues of creating these child sex dolls and child
sex robots themselves to avoid criminal sanction.
Criminals are well-known for adapting to criminal
justice measures and modifying their behaviors to
enable them to avoid these measures.163 Alarmingly,
the development of such child robots through 3D
printers is currently underway. Nanotechnology engi-
neer and adult sex robot creator (known for his devel-
opment of the sex robot “Samantha”), Sergi Santos,
has indicated that he intends to breed with the sex
robot to create a baby using a 3D printer to allow its
birth.164
WHY SHOULD THE EXISTENCE
CHILD SEX DOLLS AND ROBOTS
MATTER?
Child sex dolls and robots are the embodi-
ment of the uncanny valley—the negative emotional
response (e.g., revulsion and uneasiness) experienced
by individuals when they encounter an entity that is
close to human but not human.165 However, the mere
existence and look of child sex dolls and robots, is
not the only thing that makes166 (and should make)
humans wary of them, it is their potential use and its
implications for society.
Society needs to be concerned when single/
divorced child sex doll and robot owners abandon
attempts to have social relationships with human
partners. Psychoanalytic self-psychology indicates
that people use dolls as self-objects to feed their
narcissistic experiences.167 Adult sex dolls and robots
are advertised as providing sexual and non-sexual
companionship168 and meeting the needs of lonely
individuals (primarily men) to meet their unfilled
sexual needs and desires. While these sex dolls and
robots are promoted as a “cure” for loneliness, they
result in the opposite; these objects further isolate
humans by removing them from contact with other
human beings. The reality is that the creation of ana-
tomically correct life-like dolls and robots serve one
purpose—to be sex objects for their owners. If com-
panions were sought to teach individuals about social
relationships, then non-anatomically correct dolls
and robots would suffice and could be utilized—not
dolls and robots with orifices that are designed to fit
adult male penises. Companionship involves a two-
way relationship, which does not exist with dolls and
robots. These objects merely provide a one-way rela-
tionship and are designed purely to satisfy the owner’s
needs. One-sided relations distort reality when faced
with humans who could never meet the standards set
by these owners for a potential partner (who is always
young, beautiful, never talks back or says negative
things, etc.). Owners also will habituate to sexual acts
on child dolls and robots, deluding them into believ-
ing it is the norm. Therefore, sex dolls and robots
have the potential of altering individuals’ views and
perceptions of relationships, ultimately, having them
interact with humans as they would with the dolls
and robots.
Child sex dolls and robots actively promote and
silently endorse the notion that children are owned,
objects, and have no legal rights for independence,
thereby making them particularly ideal for sexual
abuse by pedophiles, contradicting society’s obliga-
tion to protect them.169 These objects reinforce views
that children are compliant, obedient, ever-available

JOURNAL OF INTERNET LAW December 2017
16
and submissive when it comes to sex, and if they
are not, they should be. Sex robot enthusiasts have
publicly expressed the desire for such a robot (albeit
adult versions).170 Sex dolls and robots can be totally
controlled by their owner; thus, the voice the doll
or robot has is the voice given by the person who
controls it. For example, some sex doll owners have
created social media accounts for their sex dolls, such
as Twitter, and post about what their dolls would
purportedly say.171 The owner of the robot creates
the robot’s personality. Beyond the initial settings
of the robot based on the owner’s preferences, the
robot will learn about the preferences, wants, desires,
and needs of its owner and cater to him. This is the
way current adult sex robots are marketed. A case
in point is Harmony: “Harmony smiles, blinks and
frowns. She can hold a conversation, tell jokes and
quote Shakespeare. She’ll remember your birthday, …
what you like to eat, and the names of your brothers
and sisters. She can hold a conversation about music,
movies and books. And of course, Harmony will have
sex with you whenever you want.”172
Further support that amendments to laws are
needed to prevent the creation, importation, pos-
session, and use of child sex dolls and robots is
based on psychological research on people’s rela-
tionships with dolls and robots (i.e., relational arti-
facts). People attempt to have a relationship with
relational artifacts beginning with virtual creatures/
toys (AIBOs, Furbies, My Real Babies, Tamagotchis,
etc.) in 1997.173 Research shows that “relational
artifacts provoke strong feelings’ ” in both children
and adults.174 Individuals consider them to be ‘alive’
and have an emotional attachment that encourages
companionship. Children with various virtual toys
(different from transitional toys, like teddies, which
have a static role as opposed to the latter that have
an active role shaping children’s emotional connec-
tion) and the elderly in nursing homes bonded with
robot baby dolls.175 Adult owners of AIBO pet robot
dogs or handlers of IED-defusing robot dogs not only
anthropomorphized them, but also developed intense
(one-sided) ‘relationships’ with them.176
Unlike animal sexuality, the goal of which is
purely reproductive, human sexuality predominantly
occurs for “pleasure and bonding.”177 Many men who
own multiple sex dolls and robots have a preference for
one over the rest and have married her.178 Although
some sex doll and robot owners are single, many are
married to real women. A Spanish company, Synthea
Amatus, sells a sex robot that has a ‘sex’ and ‘family’
mode. Married men with families have incorporated
them into their family unit, allowing the sex robot to
engage sexually with the couple in the bedroom and
to sit on the couch to talk with their children. Arran
Squire, the co-creator of Samantha, brings the robot
home and has it interact with his children, who, at
the time of his disclosure of these interactions, were
3-years-old and 5-years-old.179 By including adult or
child sex dolls and robots into family interactions,
children will be at risk for sexual exploitation and
abuse. The fact that the parents are accepting of the
robot may signal to the child that the behaviors that
the robot is communicating and/or engaging in are
acceptable as well. The sex doll or robot can discuss
sexual interactions with the child and expose them
to sexual activities. In this manner, children may
learn sexualized behavior from the sex doll or robot.
In essence, the sex doll or robot can ‘teach’ the child
how to please an adult and socialize the child through
interactions and discussions explaining that sexual
acts with adults are normal behavior (i.e., groom
them).
Robots can learn human behavior and adopt
norms, values, and beliefs introduced to them and
learned by them. Programmable child sex dolls
and child AI robots do not mimic the thoughts and
actions of children. They learn through observa-
tion and mimicking the behaviors of the owner and
learn the owner’s concept of desirable behavior (i.e.,
adult-child sexual activity), which is not necessarily
consistent with societal beliefs (i.e., sexual abuse and
exploitation of children is wrong). This informa-
tion can then be communicated to real children, if
they reside in the home where the child sex doll or
robot is and/or if they are brought by the pedophile
to interact with the doll or robot. Accordingly, five
different types of harm could result from children’s
exposure to and interactions with child sex dolls
and robots: (1) harm from showing age inappropri-
ate sexually-related objects/images (sex toys/people
engaging in sex, adult/child or child/child sex);
(2) harm from sexual exploitation; (3) harm from
exposure to sexually-related activities (seeing guard-
ians’ or parents’ sexual interactions with the sex doll
or robot); (4) harm from ‘teaching’ age inappropriate
behaviors (i.e., grooming them to engage in sex acts
and learning sexualized behavior from them through

December 2017 JOURNAL OF INTERNET LAW
17
modeling); and (5) harm from teaching children
beliefs that are not held by mainstream society (cor-
rupting them).
The mere existence and use of child sex dolls
and robots in themselves are dangerous for a number
of reasons. First, they give false belief to society that
‘real’ children will be safe from pedophiles. Second,
they prevent pedophiles from the responsibility of
trying to control their urges or even to prevent them-
selves from engaging in their harmful thoughts and
actions (e.g., rape of children). In fact, they encour-
age pedophiles through rewards and pleasure from
their use to continue pedophilic practices and to seek
confirmation of such practices from other pedophiles.
It also solidifies their child abuse/exploitation sche-
mas and related concepts. Third, they fail to provide
pedophiles with accurate emotional feedback from
aggressive actions, particularly ones that would result
in emotional and physical damage if performed on a
real child. Fourth, they facilitate pedophiles’ progres-
sion from mere desires and thoughts to combining
desires, thoughts, and actions. The assumption that
the child sex doll or robot will suffice as the receiver of
this combination is unfounded by scientific research
and knowledge. Fifth, they normalize the thoughts
and behaviors towards children considered by society
to be undesirable and dangerous, including that chil-
dren are objects to be used for sexual gratification.
In the absence of therapy, perverted sexual impulses
will not be explicitly censored and thus will continue
and evolve. Sixth, they make enticing models for the
grooming and training of real children in sexual abuse
and exploitation. Finally, they encourage pedophiles
to abandon emotional connections with humans in
favor of one-side relationships that further exacerbate
their ability to understand how their warped belief
system and actions affect children’s well-being.
The scientific community today has evidence
that would support the original claim of various
harms from virtual child pornography, directly and
indirectly, and we propose by extension, from child
sex dolls and robots. The arguments that child sex
dolls and robots can serve as substitutes/replacements
for using real children, could be implemented as
therapeutic cures to the harming of real children, or
the actions performed by the pedophiles on the child
sex dolls or robots do not in themselves cause harm,
are all flawed. Even if real children are not involved
in the production of child sex dolls and child sex
robots they could be harmed thereafter by users of
these objects. As Jon Brown, the head of develop-
ment at the UK National Society for the Prevention
of Cruelty to Children (NSPCC), rightly points out,
“there is a risk that those using these child sex dolls
or realistic props could become desensitized and their
behavior becomes normalized to them, so that they
go on to harm children themselves, as is often the
case with those who view indecent images.”180 If the
declaration made by the court in New York v. Ferber
that “safeguarding the physical and psychological
well-being of a minor”181 and preventing the “sexual
exploitation and abuse of children constitutes a
government objective of surpassing importance,”182
then child sex dolls and robots should be prohibited
outright by law.
NOTES
1. Mary DeYoung, “The good touch/bad touch dilemma,” Child
Welfare, 67:10 (1988), 60-68.
2. Jonathan Montgomery, “Children as property?” Modern Law
Review, 51:3 (1988), 323-342.
3. Brian Starks and Robert Robinson, “Who values the obedient
child now? The religious factor in adult values for children
1986-2002,” Social Forces, 84:1 (2005), 343-359.
4. David Finkelhor, “Early and long-term effects of child sexual
abuse: An update,” Professional Psychology: Research & Practice,
21:5 (1990), 325-330.
5. The term “child sex offender” will not be used because there are
some individuals who are not pedophiles but commit sex offenses
against children for other reasons (e.g., easy to overpower).
6. Harvard University, “Pessimism about Pedophilia,” Harvard
Health Publications, July 2010, https://www.health.harvard.edu/
newsletter_article/pessimism-about-pedophilia.
7. Lauren R. Shapiro and Marie-Helen Maras, Multidisciplinary
investigation of child maltreatment (Burlington, MA: Jones &
Bartlett Learning, 2015).
8. Snapp & Son, Inc. v. Puerto Rico, 458 U.S. 592 (1982); Robin R.
Wilson, “Sex play in virtual worlds,” 66 Washington & Lee Law
Review 1127, 1133–1134 (2009), http://scholarlycommons.law.wlu.
edu/wlulr/vol66/iss3/9, accessed 10/22/2017.
9. Carolyn C. Ross, “Overexposed and under-prepared: The effects
of early exposure to sexual content,” Psychology Today, August 13,
2012, https://www.psychologytoday.com/blog/real-healing/201208/
overexposed-and-under-prepared-the-effects-early-exposure-sexual-content.
10. Lindsay Schlegel, “These recent trends against objectifying ads
give us hope for media,” Culture, August 25, 2017, https://verilymag.
com/2017/08/britain-regulations-objectifying-ads-france-ban-too-thin-
models-women-not-objects-madonna-badger-news-08282017.
11. Ross, supra n.9.
12. Both France and the United Kingdom have specific guidelines for
ads to prevent ‘sexist and discriminatory ads’ that promote gender
stereotypes, sexually objectify women, or promote an unhealthy
body image. See Women in the World, “Britain to ban all ads that
objectify women or promote gender stereotypes,” New York Times,
July 19, 2017, http://nytlive.nytimes.com/womenintheworld/2017/07/19/
britain-to-ban-all-advertisements-that-objectify-women-or-promote-gender-
stereotypes/.

JOURNAL OF INTERNET LAW December 2017
18
13. Jane Pritchard, “The sex work debate,” International Socialism 125
(January 5, 2010), http://isj.org.uk/the-sex-work-debate/.
14. Robin Fretwell Wilson, “Sex play in virtual worlds,” Washington
and Lee Law Review, 66:3 (2009), 1127-1174.
15. Marie-Helen Maras, Cybercriminology (New York: Oxford
University Press, 2016).
16. Michael J. Hooi, “Substantive due process Sex toys after
Lawrence Williams v. Morgan, 478 F. 3d 1316 (11th Cir. 2007),”
Florida Law Review, 60:2 (2008), 507.
17. Sarah Valverde, “The modern sex doll-owner: A descriptive
analysis” (Thesis presented to California State Polytechnic
University at San Luis Obispo, 2012).
18. Veronica Cassidy, “For the love of doll(s): A patriarchal night-
mare of cyborg couplings,” English Studies in Canada, 42:1-2
(2016), 204.
19. Valverde, supra n.17 at 12.
20. Id. at 9.
21. Id. at 10.
22. Beth Timmins, “New Sex Robots With ‘Frigid’ Settings Allow
Men to Simulate Rape” The Independent, July 19, 2017, http://
www.independent.co.uk/life-style/sex-robots-frigid-settings-rape-
simulation-men-sexual-assault-a7847296.html.
23. Id.
24. Helen Heath, “Using/abusing fembots,” Overland, 225
(Summer 2016), https://overland.org.au/previous-issues/issue-225/
feature-helen-heath/.
25. Jenny Kleeman, “The race to build the world’s first sex robot,”
The Guardian, April 27, 2017, https://www.theguardian.com/
technology/2017/apr/27/race-to-build-world-first-sex-robot.
26. Valverde, supra n.17 at 10.
27. Sophie Gallagher, “The world’s first talking sex robot can
make terrible dinner conversation,” The Huffington Post UK,
April 4, 2017, http://www.huffingtonpost.co.uk/entry/talking-sex-
doll-harmony-20-realdoll_uk_58e357d7e4b0d0b7e16424b9; Sophie
Gallagher, “This robotic sex doll isn’t just looking for a one
night stand, she wants to meet your parents,” The Huffington
Post UK, March 22, 2017, http://www.huffingtonpost.co.uk/
entry/silicon-samantha-robotic-sex-doll-artificial-intelligence_uk_
58d10070e4b00705db524e04.
28. Koen Berghuis, “Brothel buys second doll because first one called
‘Fanny’ is more popular than its actual working girls,” The Mirror,
August 21, 2017, http://www.mirror.co.uk/news/world-news/brothel-
buys-second-sex-doll-11026656; Harvey Day, “First sex doll-only
brothel opens in Germany following success of Austrian outlet as
bizarre trend breeds across Europe,” DailyMail, October 18, 2017,
http://www.dailymail.co.uk/news/article-4993528/First-sex-doll-
brothel-opens-Germany.html.
29. Roc Morin, “Can Child Dolls Keep Pedophiles
from Offending?” The Atlantic, January 11, 2016,
https://www.theatlantic.com/health/archive/2016/01/
can-child-dolls-keep-pedophiles-from-offending/423324/.
30. Id.
31. The larger models’ battery drains quickly because of the size of
the dolls and robots.
32. Tanya Sweeney, “Sex robots: even better than the real thing?”
The Irish Times, October 29, 2017, https://www.irishtimes.com/
life-and-style/people/sex-robots-even-better-than-the-real-thing-
1.3065661.
33. Meghan Laslocky, “Just like a woman,” Salon, October 11, 2005,
https://www.salon.com/2005/10/11/real_dolls/.
34. Matthias Scheutz, “The Inherent Dangers of Unidirectional
Emotional Bonds Between Humans and Social Robots,” In
P. Lin, K. Abney, and G. Bekey (Eds.), Robot Ethics: The Ethical
and Social Implications of Robotics (Cambridge, MA: MIT Press,
2012), 205.
35. David Moye, “Sex robot molested at electronics festival, creators
say,” The Huffington Post, September 29, 2017, https://www.
huffingtonpost.com/entry/samantha-sex-robot-molested_us_
59cec9f9e4b06791bb10a268.
36. 18 U.S.C. §§ 2251, 2252.
37. 18 U.S.C. § 2252A.
38. Maras, supra n.15.
39. Osborne v. Ohio, 495 U.S. 103, 110-111 (1990).
40. New York v. Ferber, 458 U.S. 747, 761 (1982).
41. Id.
42. Department of Justice, “Citizen’s Guide to U.S. Federal Law
on Child Pornography,” https://www.justice.gov/criminal-ceos/
citizens-guide-us-federal-law-child-pornography.
43. Ashcroft v. Free Speech Coalition, 535 U.S. 234 (2002).
44. Id. at 250.
45. Section 2256(8)(B) of the Child Pornography Prevention Act of
1996.
46. Ashcroft, 535 U.S. 234.
47. Id., citing Stanley v. Georgia, 394 U.S. 557, 566 (1969).
48. David Finkelhor and Richard Ormrod, Child pornography:
Patterns from the NIBRS (Washington, D.C.: US Department of
Justice, Office of Justice Programs, Office of Juvenile Justice and
Delinquency Prevention, 2004).
49. Michael C. Seto, James M. Cantor, and Ray Blanchard, “Child
pornography offenses are a valid diagnostic indicator of pedo-
philia,” Journal of Abnormal Psychology, 115:3 (2006), 610-615.
50. Carissa Byrne Hessick, “Disentangling Child Pornography from
Child Sex Abuse,” Washington University Law Review, 88:4
(2011), 875.
51. Neil Malamuth and Mark Huppin, “Drawing the Line on
Virtual Child Pornography: Bringing the Law in Line with the
Research Evidence,” NYU Review of Law & Social Change 31:4
(2007), 794; Ron Langevin and Suzanne Curnoe, “The Use
of Pornography During the Commission of Sexual Offense,”
International Journal of Offender Therapy and Comparative
Criminology 48:5 (2004), 572.
52. United States Senate, Hearing before the Committee on the
Judiciary, “Stopping Child Pornography: Protecting our Children
and the Constitution: Before the Senate Comm. On the
Judiciary,” 107th Congress, Second session (statement of Ernie
Allen, Director, The National Center for Missing and Exploited
Children, October 2, 2002); Seto, Cantor, and Blanchard, supra
n.49 at 605.
53. Seto, Cantor, and Blanchard, supra n.49 at 605.
54. Supra n.52.
55. Note: Not all courts agree on this matter.
56. Drew A. Kingston, Paul Fedoroff, Philip Firestone, Susan Curry,
and John M. Bradford, “Pornography Use and Sexual Aggression:
The Impact of Frequency and Type of Pornography Use on
Recidivism Among Sexual Offenders,” Aggressive Behavior
34:4 (2008), 341-351; “Enhancing Child protection laws After
the April 16, 2002 Supreme Court Decisions, Ashcroft v. Free
Speech Coalition,” Hearing Before the Subcommittee on Crime,
Terrorism, and Homeland Security of the Homeland Security
Committee on the Judiciary, 107th Congress, 2002; United
States v. Lebovitz, 401 F. 3d 1263, 1271 (11th Cir. 2005),
Megan Westenberg, “Establishing the Nexus: The Definitive
Relationship between Child Molestation and Possession of Child
Pornography as the Sole Basis for Probable Cause,” University of
Cincinnati Law Review 18:1 (2012), 347-352.
57. Seto, Cantor, and Blanchard, supra n.49 at 610-615.
58. Bernadette H. Schell, Patrick C.K. Hung, Miguel Vargas Martin,
and Luis Rueda. “Cyber child pornography: A review paper of the

December 2017 JOURNAL OF INTERNET LAW
19
social and legal issues and remedies—a proposed technological
solution,” Aggression and Violent Behavior, 12:1 (2007), 45-63.
59. Id.; Ann Wolbert Burgess, Cheryl Regehr, and Albert R. Roberts,
Victimology: theories and applications (Burlington, MA: Jones and
Bartlett, 2010), 374; Maras, supra n.15.
60. Joe Sullivan and Anthony R. Beech, “Assessing Internet sex
offenders,” In Martin C. Calder (Ed.), Child sexual abuse and the
Internet: tackling the new frontier (Lyme Regis, UK: Russell House,
2004), pp. 69-83.
61. Suzanne Ost, ‘‘Children at risk: legal and society perceptions of
the potential threat the possession of child pornography poses to
society’’ Journal of Law and Society 29:3 (2002), 436–460.
62. Turner Broadcasting System, Inc. v. FCC, 520 U.S. 180, 212 (1997).
63. BBC News, “Andrew Dobson jailed for ‘child-like’ sex doll
import bid,” June 23, 2017, http://www.bbc.com/news/uk-england-
stoke-staffordshire-40383627; Colin Adwent, “Bury St Edmunds
man spared jail over child sex doll and 35,000 indecent images
of children,” East Anglian Times, July 22, 2017, http://www.
eadt.co.uk/news/bury-st-edmunds-man-spared-jail-over-child-sex-
doll-and-35-000-indecent-images-of-children-1-5117046; Norfolk
Constabulary, “Norwich man sentenced for importing obscene
doll,” August 25, 2017, https://www.norfolk.police.uk/news/latest-
news/norwich-man-sentenced-importing-obscene-doll; Lizzie Deadren,
“Man sentenced for importing childlike sex doll from Hong Kong,”
The Independent, September 29, 2017, http://www.independent.
co.uk/news/uk/crime/simon-glerum-child-sex-doll-guilty-sentence-jail-
latest-court-trial-essex-hong-kong-indecent-obscene-a7973876.html.
html; BBC News, “Childlike sex doll man given suspended prison
term,” September 29, 2017, http://www.bbc.com/news/uk-england-
essex-41444602; National Crime Agency, “Ex-school governor
and church warden guilty in landmark child sex doll ruling,” July
31, 2017, http://www.nationalcrimeagency.gov.uk/news/1163-ex-
school-governor-and-church-warden-guilty-in-landmark-child-sex-doll-
ruling; Reuters Staff, “Briton convicted of importing child sex
doll in landmark case,” Reuters, July 31, 2017, https://www.reuters.
com/article/us-britain-crime-doll/briton-convicted-of-importing-child-
sex-doll-in-landmark-case-idUSKBN1AG1JS; BBC News, “child
sex doll an obscene item, judge rules,” July 31, 2017, http://www.
bbc.com/news/uk-40776622; BBC News, “Ex-school governor who
imported child sex doll is jailed,” September 8, 2017, http://www.
bbc.com/news/uk-41203239; Crown Prosecution Service, “Prison
sentence for child sex doll importation,” September 8, 2017,
http://www.cps.gov.uk/southeast/cps_southeast_news/prison-sentence-
for-child-sex-doll-/; Francesca Gillett, “Paedophile who bought
life-size child sex doll on internet spared jail,” Evening Standard,
September 1, 2017, https://www.standard.co.uk/news/uk/paedophile-
who-bought-lifesize-child-sex-doll-on-internet-spared-jail-a3625356.html.
html; BBC News, “Brian Hopkins, smuggler of child sex doll,
given suspended sentence,” September 1, 2017, http://www.bbc.
com/news/uk-england-devon-41130328.
64. Jamy Li, “The benefit of being physically present: A survey of
experimental works comparing copresent robots, telepresent
robots and virtual agents,” International Journal of Human-
Computer Studies, 77:C (2015), 23–37.
65. Miller v. California, 413 U.S. 15, 25 (1973).
66. Paris Adult Theater I v. Slaton, 413 U.S. 49, 69 (1973).
67. Roth v. United States, 354 U.S. 476 (1957).
68. The First Amendment holds: “Congress shall make no law
respecting an establishment of religion, or prohibiting the free
exercise thereof; or abridging the freedom of speech, or of the
press; or the right of the people peaceably to assemble, and to
petition the Government for a redress of grievances.” Other
forms of unprotected speech include: intellectual property—
Harper & Row, Publishers, Inc. v. Nation Enterprises, 471 U.S.
539 (1985); fighting words—Chaplinsky v. New Hampshire, 315
U.S. 568 (1942); false statement of facts—Gertz v. Welch, 418
U.S. 323 (1974); true threats—Watts v. United States, 394 U.S.
705 (1969); incitement to violence—Brandenburg v. Ohio, 395
U.S. 444 (1969); and obscene speech—Roth v. United States,
354 U. S. 476 (1957); Miller v. California, 413 U.S. 15 (1973).
69. Morin, supra n.29; Press Association, “Man who tried to import
childlike sex doll to UK is jailed,” The Guardian, June 23, 2017,
https://www.theguardian.com/uk-news/2017/jun/23/man-import-
childlike-sex-doll-uk-jailed; CDPP, Australia’s Federal Prosecution
Service, “Man in possession of child sex doll sentenced to
imprisonment,” August 19, 2016, https://www.cdpp.gov.au/
news/man-possession-child-sex-doll-sentenced-imprisonment; Carla
Penman, “Customs seize sex dolls with child-like faces,” New
Zealand Herald, July 7, 2017, http://www.nzherald.co.nz/nz/news/
article.cfm?c_id=1&objectid=11887417.
70. Rachael Revesz, “Canadian court to determine whether child sex
doll constitutes child pornography,” The Independent, February 13,
2017, http://www.independent.co.uk/news/world/americas/canada-
court-child-sex-doll-pornography-paedophilia-newfoundland-kenneth-
harrison-a7578321.html.
71. Roth v. United States, 354 U.S. 476, 489 (1957).
72. Id. at 487 n.20.
73. Miller v. California, 413 U.S. 15 (1973).
74. Id. at 24-25.
75. Miller, 413 U.S. 15 .
76. L. Rowell Huesmann, “The role of social information processing
and cognitive schema in the acquisition and maintenance of habit-
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social policy (San Diego, CA: Academic Press, 1998), 73-109.
77. Shapiro and Maras, supra n.7 at 48-49.
78. Id.
79. Bryant Paul and Daniel Linz, “The effects of exposure to virtual
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80. Id.
81. L. J. Shrum, “Media consumption and effects of social reality:
Effects and underlying processes,” In Jennings Bryant & Dolf
Zillman (Eds.), Media effects: Advances in theory and research
(2nd ed.) (Mahwah, NJ: Lawrence Erlbaum, 2002), 69-95.
82. Ronald Akers, Social Learning and Social Structure: A General
Theory of Crime and Deviance (Boston, MA: Northeastern
University Press, 1998).
83. Thomas J. Holt, Kristie R. Blevins, and Natasha Burkert,
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A Journal of Research and Treatment, 22:1 (2010), 3-24.
84. Morin, supra n.29.
85. Shapiro and Maras, supra n.7 at 107.
86. Id.
87. Id.
88. Id.
89. Id. at 106-107.
90. Burrhus Frederic Skinner, Science and human behavior (New York:
Free Press, 1953); Burrhus Frederic Skinner, Beyond freedom and
dignity (New York: Knopf, 1971); Ronald L. Akers, “Rational
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81:3 (1990), 653-676.
91. A. Charles Catania (ed.), Contemporary research in operant behav-
ior (Glenview, IL: Scott Foresman and Company, 1968); Howard
Rachlin, Introduction to modern behaviorism (San Francisco, CA:
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Barbara L. Anderson, Behavior modification (New York: Random
House, 1979).

JOURNAL OF INTERNET LAW December 2017
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92. Thomas Arnold and Matthias Scheutz, “The tactile ethics of
soft robotics: Designing wisely for human-robot interaction.”
Soft Robotics, 4:2 (2017), 81-87.
93. Id.
94. Thomas Arnold and Mattias Scheutz, “Beyond moral dilemmas:
Exploring the ethical landscape in HRI” (HRI, Vienna, Austria.
March 6-10, 2017).
95. Matthias Scheutz, “The Inherent Dangers of Unidirectional
Emotional Bonds Between Humans and Social Robots,” In P. Lin,
K. Abney, and G. Bekey (Eds.), Robot Ethics: The Ethical and Social
Implications of Robotics (Cambridge, MA: MIT Press, 2012), 205.
96. Jamy Li, Wendy Ju, and Byron Reeves, “Touching a mechanical
body: Tactile contact with intimate parts of a humanoid robot
is physiologically arousing,” The 66th Annual International
Communication Association in 2016, Conference.
97. Shapiro and Maras, supra n.7 at 107.
98. Id. at 104-105, 108
99. Id. at 106-108
100. Id. at 107.
101. Id.
102. Id.
103. Id. at 183-193.
104. Albert Bandura, Social foundations of thought and action: A social
cognitive theory (Englewood Cliffs, NJ: Prentice Hall, 1986).
105. Paul and Linz, supra n.79.
106. Daniel Linz, Edward Donnerstein and Steven Adams,
“Physiological desensitization and judgements about female vic-
tims of violence,” Human Communication Research 15:4 (1989),
509-522.
107. Paul and Linz, supra n.79.
108. Mattias Scheutz and Thomas Arnold, “Intimacy, bonding, and
sex robots: Examining empirical results and exploring ethical
ramifications” (Unpublished manuscript, 2017), https://hrilab.
tufts.edu/publications/scheutz2017intimacy.pdf.
109. Id.
110. Emily Chen, “Police break into car to rescue an ‘abandoned
baby’ … which turns out to be an ultra-realistic doll,” August 17,
2016, http://www.dailymail.co.uk/news/article-3745066/Lifelike-
doll-hot-car-prompts-police-smash-window.html.
111. Laslocky, supra n.33.
112. Mattias Scheutz and Thomas Arnold, “Are we ready for sex
robots?” Proceedings of the 11th ACM/IEEE Conference on
Human-Robot interaction, 2016; Scheutz and Arnold, supra n.108.
113. Id.
114. Rachael Revesz, “Paedophiles ‘could be prescribed child sex
dolls’ to prevent real attacks, says therapist,” The Independent,
August 2, 2017, http://www.independent.co.uk/news/uk/home-
news/paedophiles-child-sex-dolls-prescription-stop-attacks-child-
protection-stopso-therapists-a7872911.html; James McCarthy,
“Welsh charity criticized after suggesting child sex dolls
should be made available on prescription.” WalesOnline,
August 2, 2017, http://www.walesonline.co.uk/news/wales-news/
welsh-charity-criticised-after-calling-13422072.
115. National Crime Agency, “Ex-school governor and church
warden guilty in landmark child sex doll ruling,” July 31,
2017, http://www.nationalcrimeagency.gov.uk/news/1163-ex-
school-governor-and-church-warden-guilty-in-landmark-child-
sex-doll-ruling.
116. Laslocky, supra n.33.
117. Shadd Maruna, and Ruth E. Mann, “A fundamental attribution
error? Rethinking cognitive distortions,” Legal and Criminological
Psychology, 11:2 (2006), 155; Gene G. Abel, David K. Gore,
C. L. Holland, Nancy Camp, Judith V. Becker, and Jerry Rathner,
“The measurement of the cognitive distortions of child molesters,”
Annals of Sex Research, 2:2 (1989), 135–153; Shapiro and Maras,
supra n.7; Dennis Howitt and Kerry Sheldon, “The role of cogni-
tive distortions in paedophilic offending: Internet and contact
offenders compared,” Psychology, Crime and Law, 13:5 (2007)
469-486.
118. Roger Przybylski, “Effectiveness of treatment for adult sex
offenders,” In Office of Justice Programs, Sex offender
management assessment and planning initiative, July 2015,
https://www.smart.gov/SOMAPI/sec1/ch7_treatment.html;
R. Karl Hanson, Guy Bourgon, Lesley Helmus, and Shannon
Hodgson, A Meta-Analysis of the Effectiveness of Treatment for
Sex Offenders: Risk, Need, and Responsivity (Ottawa, Ontario,
Canada: Public Safety Canada, 2009), 195-197.
119. Harvard University, supra n.6.
120. Shapiro and Maras, supra n.7 at 183-193.
121. Robert Lee Pierce, “Child Pornography: A Hidden Dimension
of Child Abuse,” Child Abuse and Neglect, 8:4 (1984), 483-493;
Heather Wood, “Internet pornography and paedophilia,”
Psychoanalytic Psychotherapy, 27:4 (2013), 319-338.
122. Albert Bandura, “Selective Moral Disengagement in the
Exercise of Moral Agency,” Journal of Moral Education, 31:2
(2002), 108-109; Maras, supra n.15.
123. Neil Levy, “Virtual child pornography: The erotization of
inequality,” Ethics and Information Technology, 4:4 (2002),
319-323.
124. Id.
125. Hanna Roos, “Trading the sexual child: Child pornography and
the commodification of children in society,” Texas Journal of
Women and Law, 23:2 (2014), 131-156.
126. Id. at 145.
127. Levy, supra n.123.
128. Roos, supra n.125 at 146.
129. Mary Eberstadt and Mary Anne Layden, The social costs
of pornography: A statement of findings and recommendations
(Princeton, New Jersey: Witherspoon Institute, Inc., 2010);
Chung Sun, Ana Bridges, Jennifer A. Johnson, and Matthew B.
Ezzell, “Pornography and the male sexual script: An analysis of
consumption and sexual relations,” Archives of Sexual Behavior,
45:4 (2016), 983-994.
130. Daniel Linz, Edward Donnerstein and Steven Adams, supra
n.106.
131. W.L. Marshall, “Pornography and sex offenders,” In Dolf
Zillman and Jennings Bryant (Eds.), Pornography: Research
Advances and policy considerations (Hillsdale, NJ, England:
Lawrence Erlbaum Associates, Inc., 1989), 185-214. Daniel
Lee Carter, Robert Alan Prentky, Raymond A. Knight, Penny
L. Vanderveer, and Richard J. Boucher, “Use of Pornography
in the Criminal and Developmental Histories of Sexual
Offenders,” Journal of Interpersonal Violence, 2:2 (June 1987),
196-211.
132. Jenny A.B.M. Houtepen, Jelle J. Sijtsema, and Stefan
Bogaerts, “From child pornography to child sexual abuse: A
review of child pornography offender characteristics and risks
for cross-over.” Aggression and Violent Behavior, 19:5 (2014),
466-473.
133. Glenn D. Wilson, The great sex divide: A study of male-female
differences (Washington DC: Scott-Townsend Publishers, 1992).
134. Id. at 41-45.
135. Rhian Morgan, “Looking for robot love? Here are 5 sexbots you
can buy right now,” Metro, September 13, 2017, http://metro.
co.uk/2017/09/13/looking-for-robot-love-here-are-5-sexbots-you-
can-buy-right-now-6891378/.

December 2017 JOURNAL OF INTERNET LAW
21
136. Ashcroft, 122 S. Ct. 1389, 1404.
137. Stanley v. Georgia, 394 U.S. 557, 566 (1969).
138. Id. at 565.
139. Osborne v. Ohio, 495 U.S. 103 (1990).
140. Section 502 of the Protect Act of 2003.
141. See United States v. Irving, 452 F.3d 110 (2d Cir. 2006) and
United States v. Rodriguez-Pacheco, 475 F. 3d 434 (1st Cir.
2007).
142. 18 U.S.C. § 1466A(a).
143. 18 U.S.C. § 1466A(b).
144. United States v. Whorley, 550 F.3d 326, 331 (4th Cir., 2008).
145. US District Court for the District of Idaho, United States v.
Steven Kutzner, Case No. CR-10-0252-S-EJL, https://reason.
com/assets/db/12955634459236.pdf.
146. Id.
147. McFadden v. Alabama, 27 So. Ed 637 (2008); McFadden v.
Alabama, 2010 Ala. Crim. App. LEXIS 162 (Ala. Crim. App.,
Sept. 24, 2010).
148. Hotaling v. United States, 599 F. Supp. 2d 306, 2008 U.S. Dist.
Lexis 98373 (N.D.N.Y., 2008); Hotaling v. United States, 2011
U.S. LEXIS 8924 (U.S., Dec. 12, 2011).
149. Henry N. Cary, Erotic contrivances: appliances attached to, or used
in place of, the sexual organs (Chicago, IL: Privately printed,
1922), as cited in Valverde, supra n.17.
150. Erico Guizzo, “Hiroschi Ishiguro: The Man Who
Made a Copy of Himself,” IEEE Spectrum, April 23,
2010, https://spectrum.ieee.org/robotics/humanoids/
hiroshi-ishiguro-the-man-who-made-a-copy-of-himself.
151. Morin, supra n.29.
152. United States v. Ryan, Case No. 2:07-CR-35 (D. Vt. May 26,
2009).
153. United States v. Mees, No. 4:09CR00145 ERW, 2009 WL
1657420 (E.D. Mo. June 10, 2009).
154. United States v. Handley, 564 F. Supp. 2d 996, 999 (S.D. Iowa,
2008).
155. Id.
156. United States v. Dean, 635 F.3d 1200 (11th Cir. 2011).
157. Lizzie Deadren, “Man sentenced for importing childlike sex doll
from Hong Kong,” The Independent, September 29, 2017, http://
www.independent.co.uk/news/uk/crime/simon-glerum-child-sex-
doll-guilty-sentence-jail-latest-court-trial-essex-hong-kong-indecent-
obscene-a7973876.html.
158. BBC News, “Andrew Dobson jailed for ‘child-like sex
doll import bid,” June 23, 2017, http://www.bbc.com/news/
uk-england-stoke-staffordshire-40383627.
159. Colin Adwent, “Bury St Edmunds man spared jail over child
sex doll and 35,000 indecent images of children,” East Anglian
Times, July 22, 2017, http://www.eadt.co.uk/news/bury-st-
edmunds-man-spared-jail-over-child-sex-doll-and-35-000-indecent-
images-of-children-1-5117046.
160. Norfolk Constabulary, “Norwich man sentenced for importing
obscene doll,” August 25, 2017, https://www.norfolk.police.uk/
news/latest-news/norwich-man-sentenced-importing-obscene-doll.
161. Lizzie Deadren, “Man sentenced for importing childlike sex doll
from Hong Kong,” The Independent, September 29, 2017, http://
www.independent.co.uk/news/uk/crime/simon-glerum-child-sex-
doll-guilty-sentence-jail-latest-court-trial-essex-hong-kong-indecent-
obscene-a7973876.html.
162. BBC News, “Childlike sex doll man given suspended prison
term,” September 29, 2017, http://www.bbc.com/news/
uk-england-essex-41444602.
163. Gary T. Marx, “A tack in the shoe: Neutralizing and resist-
ing the new surveillance,” Journal of Social Issues 59:2 (2003),
369-390.
164. Lisa Guiterrez, “Sex robot creator wants to have a baby with
his machine and says it would be ‘simple,’ ” October 24, 2017,
http://www.kansascity.com/news/nation-world/article180608336.
html.
165. Masahiro Mori, “The uncanny valley,” Energy 7:4 (1970),
33-35.
166. Research cited earlier in this article reflects this as both men
and women voiced their opposition to humans having sex with
child sex robots. Arnold and Scheutz, supra n.92.
167. Sherry Turkle, “Authenticity in the age of digital companions,”
In Peter H. Kahn, Jr. and Karl F. MacDorman (eds.), Interaction
Studies: Social behavior and communication in biological and arti-
ficial systems, 8:3 (2007), 501-517. Special issue: Psychological
benchmarks of human-robot interaction. Amsterdam: John
Benjamins Publishing Company.
168. Kleeman, supra n.25.
169. Jonathan Montgomery, “Children as property?” Modern Law
Review 51:3 (1988), 323-342.
170. Dough Hines, “My Sex Robot” documentary (SBS online).
171. Emma Gritt, “Troll Dolls: Sex dolls have started making
TWITTER ACCOUNTS for their treasured rubber girl-
friends … and you won’t believe what they get up to,” The Sun,
August 10, 2017, https://www.thesun.co.uk/living/4211673/sex-
doll-owners-have-started-making-twitter-accounts-for-their-treasured-
rubber-girlfriends-and-you-wont-believe-what-they-get-up-to/.
172. Kleeman, supra n.25.
173. Sherry Turkle, “Whither psychoanalysis in the computer cul-
ture?” Psychoanalytic Psychology 21:1 (2004) 16-30.
174. Sherry Turkle, Cynthia Breazeal, Olivia Daste, and Brian
Scassellati, “First encounters with Kismet and Cog: Children’s
relationship with humanoid robots,” in Paul Messaris and Lee
Humphreys (Eds.), Digital media: Transfer in human communi-
cation (NY: Peter Lang, 2006); Sherry Turkle, Will Taggart,
Cory D. Kidd, and Olivia Daste, “Relational artifacts with
children and elders: The complexities of cybercompanionship,”
Connection Science, 18:4 (2006), 347-361.
175. Turkle, supra n.173.
176. Mattius Scheutz, “The inherent dangers of unidirectional
emotional bonds between humans and social robots. Anthology
on robo-ethics,” 2011, https://hrilab.tufts.edu/publications/scheutz-
11roboethics.pdf.
177. Gregory Lehne, “Phenomenology of paraphilia: Lovemap
Theory,” in Fabian M. Saleh, Albert J. Grudzinskas, John
M. Bradford, and Daniel J. Brodsky (eds.), Sex offenders:
Identification, risk assessment, treatment, and legal issues
(Oxford: Oxford University Press, 2009), 14.
178. Julie Beck, “Married to a doll: Why one man advo-
cates synthetic love,” The Atlantic, September 6, 2013,
https://www.theatlantic.com/health/archive/2013/09/
married-to-a-doll-why-one-man-advocates-synthetic-love/279361/.
179. This Morning with Phillip and Holly TV show, September 12,
2017, https://www.youtube.com/watch?v=AqokkXoa7uE.
180. National Crime Agency, “Ex-school governor and church
warden guilty in landmark child sex doll ruling,” July 31, 2017,
http://www.nationalcrimeagency.gov.uk/news/1163-ex-school-governor-
and-church-warden-guilty-in-landmark-child-sex-doll-ruling.
181. New York v. Ferber, 458 U.S. 747, 757 (1982), citing Globe
Newspaper Co. v. Superior Court, 457 U. S. 596, 457 U. S. 607
(1982).
182. Ferber, 458 U.S. 747.

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