included disclaimer in story headers, stating that the work is pure fiction, has so far protected real person fiction from slander and libel. The first known case of legal action being taken as a result of RPF is from 2003, when FanDomination.net received a cease and desist order from a representative of baseball player Andy Pettitte. Real person slash Real person slash (RPS), also known in some circles as real-life slash (RLS), involves relationships. (See slash fiction for more on the subtleties and variations in definition.) These are usually complete fabrications, not based on any real-life indications of the subject's sexual orientation, but on the fantasies of the author and the desire to experiment with perceived or invented erotic subtext between the idols in question. Slash is roughly equal in popularity to less controversial types of real person fiction. The content of the stories can range from the mildly romantic, involving deep friendships and innocent crushes, to carefully written love stories, all the way to explicit erotica. With the advent of bands, fans wrote an explosion of fictional stories about members being involved in romantic relations with one another. In the 1990s, early online RPS communities were devoted to depictions of bands. Most band-related RPF was slash fiction. Older RPF communities also began to see a rise in slash content, in contrast to earlier stories, which had generally featured original (non-"canon") characters as partners for band members. As slash became more acceptable, the amount of explicit sexual content in the stories also began to rise. Erotic fan stories have existed for as long as other types of fanfic, but they were often a closed-door affair, circulated only in private among friends, and it is unclear whether sexual content was a common theme. With the advent of the Internet simultaneously allowing easy distribution of stories and relative anonymity for authors, stories with explicit content suddenly became much more widespread. Due to the potentially libelous nature of some stories, and the knowledge or fear that some celebrities dislike slash fiction involving themselves, some fan fiction communities denounce RPS fiction and do not allow it on their websites. This type of RPF also brings up issues of consent and objectification of real people. Reaction In 2008, a man was arrested in the UK for writing and publishing on the internet a story featuring various members of the band Girls Aloud under the Obscene