18 U.S.C. § 2256(2) (A)(v) DEFINES THE TERM "LASCIVIOUS"
AS PART OF 18 U.S.C.
CONDUCT" ELEMENT AND IS A DEFINITION AND NOT.AN
ELEMENT ITSELF. THERE IS AN ACKNOWLEDGED AND
REOCCURRING CIRCUIT CONFLICT ON THE QUESTION OF:
WHETHER CONGRESS ALLOWS FOR A CONVICTION UNDER 18
U.S.C. §2251( a) THAT IS BASED ON:A DEFINITION AND NOT
ON THE STATUTES ELEMENTS WHICH REQUIRE SEXUAL CONDUCT
OF ANY KIND, AND.THE IMAGES DEPICT ABSOLUTLY NO SEXUAL
OR SEXUALLY SUGGESTIVE CONDUCT OF ANY:KIND.. 1 .
§2251 (a)'S "SEXUALLY EXPLICIT

Whether a conviction under 18 U.S.C. §2251(a) can be based on a definitional term 'lascivious' without depicting actual sexual conduct