 In the 1970s in the United States, attempts were made to shut down the pornography industry by prosecuting individuals on prostitution charges.In the case of "People v. Freeman", the California Supreme Court ruled to distinguish prostitution as an individual taking part in sexual activities in exchange for money versus an individual who is portraying a sexual act on-screen as part of their acting performance.The case was not appealed to the U.S. Supreme Court, thus it is only binding in the state of California.