9th Cir.;
15-30148

The court of appeals reversed a judgment of conviction. The court held that the district court erred in precluding defense counsel from arguing that the prosecution failed to prove that posts on a closed internet bulletin board constituted “notices or advertisements.”

Daniel Brown was a member of an online bulletin board known as Dark Moon, where members, including Brown, shared child pornography. Brown was tried before a jury on charges of conspiracy to make, print, or publish “any notice or advertisement seeking or offering” child pornography in violation of 18 U.S.C. §§2251(d) and (e).