1. Whether Ohio's imposition of strict liability for even
inadvertent, accidental or unknowing dissemination
of child pornography violates due process and
conflicts with the decisions of this Court requiring
scienter in obscenity laws especially in light of the
modern computer age.

2. Whether a defendant's fundamental constitutional
right to mount a defense, as recently outlined in
Holmes v. South Carolina, is violated whereby the
State acknowledges that there was no evidentiary
rule that precluded the admission of the evidence
that another person may have committed the crime.

3. Whether this Court's seminal holding in Massiah v.
United States was violated whereas the Ohio court
ruled that a law enforcement officer can interrogate
a defendant after he has been indicted without the
presence of counsel and subsequently use this
statement in the prosecution's case in chief.

4. Whether the Ohio court's decision conflicts with and
violates this Court's landmark holding in Doyle v.
Ohio wherein the prosecution first raised and
violated the defendant's right to remain silent.

Whether Ohio's strict liability for inadvertent child pornography dissemination violates due process, whether defendant's right to mount a defense was violated, whether Massiah and Doyle violations occurred