Response to “18 U.S.C. § 1466A” has been met with legal challenges on a number of fronts. On May 19, 2008, the SCOTUS again applied the holding of Ashcroft, supra, to virtual child pornography via United States v. Williams (2008). It was ruled that “an offer to provide or request to receive virtual child pornography is not prohibited by the statute. A crime is committed only when the speaker believes or intends the listener to believe that the subject of the proposed transaction depicts real children. It is simply not true that this means ‘a protected category of expression \[will\] inevitably be suppressed…Simulated child pornography will be as available as ever.” Also of issue has been the wording of “18 U.S.C. § 1466A”, where parts of the law testing the criminalization of a “visual depiction of any kind” have been tried in the courts. In October 2008, a 38-year-old Iowa comic collector named Christopher Handley was prosecuted for possession of explicit lolicon manga. The judge ruled that two parts of the PROTECT Act criminalizing “a visual depiction of any kind, including a drawing, cartoon, sculpture, or painting” were unconstitutional, but Handley still faced an obscenity charge.\[85\] Handley was convicted in May 2009 as the result of entering a guilty plea bargain at the recommendation of his lawyer, under the belief that the jury chosen to judge him would not acquit him of the obscenity charges if they were shown the images in question.\[86\]