1999. This precedent appears to have been set when the BBFC granted 18 certificates for films containing short scenes of unsimulated sex, such as Catherine Breillat's Romance (1999) and Patrice Chéreau's Intimacy (2001). In October 2004, a new precedent appeared to be set when the BBFC granted an 18 certificate for Michael Winterbottom's film 9 Songs, which featured a number of lengthy explicit scenes of unsimulated sex. This was followed by certificates for Shortbus and Destricted. In the statement justifying the latter decision, it was stated that there is no limit to the number of images that can be considered to be justified. In 2004, the board was also challenged by some pornographic video distributors to award 18 certificates to material that would otherwise be classified at R18. This could have greatly diminished the role of the R18 certificate but failed. This means there continues to be a form of artistic merit test requiring the work to be judged non-pornographic and the scenes in question "exceptionally justified by context" for a mainstream release. In its 2009 report (available on its website), the BBFC updated its standards stating that:"When it comes to sex in films for adults, the Board's policy is that explicit images of real sex should be confined to the ‘R18’ category, unless such images can be justified by their context. However, contextual justification is irrelevant if the primary purpose of the work is sexual arousal or stimulation (i.e. a sex work). Under the new Guidelines, the contextual justification for explicit images of real sex at ‘18’ no longer needs to be ‘exceptional’." The main difference between this new policy and previous years' policies is that contextual justification for images of real sex no longer needs to be "exceptional" in an 18 rated work. In its 2010 report (available on its website), the BBFC updated its standards again stating that:"As in previous years, the Board's policy remains that explicit images of real sex should be confined to the ‘R18’ category unless such images can be justified by their context. Contextual justification, however, has less weight if the primary purpose of the work is sexual arousal or stimulation (i.e. a sex work)." The main difference between this new policy and previous years' policies is that contextual justification for images of real sex is no longer irrelevant if the primary purpose of the work is sexual arousal or stimulation; instead, it