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During much of that time, any sexual depiction had to remain underground because of obscenity laws. In particular, gay material might constitute evidence of an illegal act under sodomy laws in many jurisdictions. This is no longer the case in the United States, since such laws were ruled unconstitutional by the Supreme Court in in Lawrence v. However, hardcore pornographic motion pictures stag films, as they were called prior to their legalization in were produced relatively early in the history of film. The first known pornographic film appears to have been made in Europe in

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