to society. The Court noted obscenity could encourage degrading views of women and could promote violence. This contradicted the view of Canada as a society in which people are equal. Typically, the original purpose of the law is what is considered under section 1. In this case, the Supreme Court justified itself by saying the original purpose of avoiding immorality, and the recognized purpose in this case, of preventing harm, were linked. The immorality could lead to harm. The Court also noted that Canada had international agreements that targeted obscenity, namely the Agreement for the Suppression of the Circulation of Obscene Publications and the Convention for the Suppression of the Circulation of and Traffic in Obscene Publications. With a sufficient objective identified, it now had to be asked whether the law was rational and proportionate to the objective. The Court noted, then, that the law should not affect acceptable pornography, namely the type that might celebrate female sexuality and pleasure. Material that degrade women were similar to hate speech. It was rational to outlaw obscenity in order to protect society. Although it was disputed whether obscenity truly promotes harm, some reports did support this conclusion. The courts could then defer to the Parliament of Canada on this matter. The Court found the law to be proportional. The legislation did not outlaw non-degrading erotica. Moreover, a vague definition of obscenity in the law was acceptable since politicians had difficulty in drawing up comprehensive definitions. Making the obscenity public was criminalized while private materials may not be. Framework for Analysis To simplify the analysis Justice John Sopinka divided potentially obscene materials into three categories: 1. Explicit sex with violence; 2. Explicit sex without violence, but which subjects participants to treatment that is degrading or dehumanizing; and 3. Explicit sex without violence that is neither degrading nor dehumanizing. Violence in this context was considered to include "both actual physical violence and threats of physical violence." Justice John Sopinka then went on to state that materials in the first category "will almost always constitute the undue exploitation of sex." Material in the second category "may be undue if the risk of harm is substantial." And, finally, material in the third category "is generally tolerated in our society and will not qualify as the undue exploitation of sex unless it employs children in its production." Any material that was considered to be the "undue" exploitation