areas in the United States. However, researchers had shown that guests at the local Marriott Hotel were disproportionately large consumers of pay-per-view pornographic material, accessing far more material than the store was distributing. Criticism Less strict standard may lead to greater censorship Because it allows for community standards and demands "serious" value, Justice Douglas worried in his dissent that this test would make it easier to suppress speech and expression. Miller replaced a previous test asking whether the speech or expression was "utterly without redeeming social value". As used, however, the test generally makes it difficult to outlaw any form of expression. Many works decried as pornographic have been successfully argued to have some artistic or literary value, most publicly in the context of the National Endowment for the Arts in the 1990s. Problem of jurisdiction in the Internet age The advent of the Internet has made the "community standards" part of the test even more difficult to judge; as material published on a web server in one place can be read by a person residing anywhere else, there is a question as to which jurisdiction should apply. In United States of America v. Extreme Associates, a pornography distributor from North Hollywood, California, was judged to be held accountable to the community standards applying in western Pennsylvania, where the Third Circuit made its ruling, because the materials were available via Internet in that area. The United States Court of Appeals for the Ninth Circuit has ruled in United States v. Kilbride that a "national community standard" should be used for the Internet, but this has yet to be upheld at the national level. See also Artistic merit Dost test I know it when I see it Literary merit Nitke v. Gonzales – a case involving Barbara Nitke and the National Coalition for Sexual Freedom regarding Internet obscenity Jack Thompson United States v. Extreme Associates, Inc. Notes References First Amendment to the United States Constitution Legal tests Obscenity law United States pornography law