Pornography, American adult entertainment industry has grown considerably over the past thirty years by continually changing and expanding to appeal to new markets, though the production is considered to be low-profile and clandestine. The total income of modern country's adult entertainment is often rated at $10–13 billion, of which $4–6 billion are legal. The figure is often credited to a study by Forrester Research and was lowered in 1998. In 2007 The Observer newspaper also gave a figure of $13 billion. Other sources, quoted by Forbes (Adams Media Research, Veronis Suhler Communications Industry Report, and IVD), even taking into consideration all possible means (video networks and pay-per-view movies on cable and satellite, web sites, in-room hotel movies, phone sex, sex toys, and magazines) mention the $2.6–3.9 billion figure (without the cellphone component). USA Today claimed in 2003 that websites such as Danni's Hard Drive and Cybererotica.com generated $2 billion in revenue in that year, which was allegedly about 10% of the overall domestic porn market at the time. The adult movies income (from sale and rent) was once estimated by AVN Publications at $4.3 billion but how this figure was determined is unclear. According to the 2001 Forbes data the annual income distribution is like this: The Online Journalism Review, published by the Annenberg School of Communication at the University of Southern California, weighed in with an analysis that favored Forbes number. The financial extent of adult films, distributed in hotels, is hard to estimate—hotels keep statistics to themselves or do not keep them at all. A CBS News investigation in November 2003 claimed that 50% of guests at the Hilton, Marriott, Hyatt, Sheraton, and Holiday Inn hotel chains purchased adult movies, contributing to 70% of in-room profits. The income of cellphone porn is low, when compared with other countries. The absence of V-chip-style parental controls on other equipment has obviated the need for American consumers to use cellphones to access explicit content. Legality The lawful definition of pornography in the U.S. evolved through decades, from the 1960s. In this period, recognizing ambiguities, the term "sexually explicit content" gained use as one of the pornography's euphemisms, but later it was determined that a distinction between pornographic and sexually explicit content is completely artificial. In Miller v. California the Supreme Court used the definition of pornography made by Webster's Third New International Dictionary of 1969 ("a depiction (as in a writing