victims. In another English case in 2009, R v Wilkins (2010), a man who filmed his intercourse with five of his lovers for his own private viewing was sentenced to eight months in prison and ordered to sign onto the Sex Offender Register for ten years. In 2013, 40-year-old Mark Lancaster was found guilty of voyeurism and jailed for 16 months, after he tricked an 18-year-old student into traveling to a rented flat in Milton Keynes, where he filmed her with four secret cameras dressing up as a schoolgirl and posing for photographs before he had sex with her. In a more recent English case in 2020, the Court of Appeal upheld the conviction of Tony Richards after Richards sought "to have two voyeurism charges under section 67 of the Sexual Offences Act dismissed on the grounds that he had committed no crime". Richards "secretly videoed himself having sex with two women who had consented to sex in return for money but had not agreed to being captured on camera". In an unusual step, the court allowed Emily Hunt, a person not involved in the case, to intervene on behalf of the Crown Prosecution Service (CPS). Hunt had an ongoing judicial review against the CPS since the CPS had argued that Hunt's alleged attacker had not violated the law when he "took a video lasting over one minute of her naked and unconscious" in a hotel room on the basis that there should be no expectation of privacy in the bedroom. However, in terms of what is considered a private act for the purposes of voyeurism, the CPS was arguing the opposite in the Richards appeal. The Court of Appeal clarified that consenting to sex in a private place does not amount to consent to be filmed without that person's knowledge. Anyone who films or photographs another person naked, without their permission, is breaking the law under sections 67 and 68 of the Sexual Offences Act. In the United States, video voyeurism is an offense in twelve states and may require the convicted person to register as a sex offender. The original case that led to the criminalisation of voyeurism has been made into a television movie called Video Voyeur and documents the criminalisation of secret photography. Criminal voyeurism statutes are related to invasion of privacy laws but are specific to unlawful surreptitious surveillance without consent and unlawful recordings including