United States v. Knowlton, 993 F.3d 354

Knowlton lived in Texas; law enforcement executed a search warrant after two child‑pornography videos were traced to his IP address. Eighteen devices in his home contained 3,469 unique images and 249 unique videos of child pornography.
Files included images of infants/toddlers, violent content, and at least two videos of identified child‑abuse victims; longest video was nearly three hours.
Files were obtained via a peer‑to‑peer network and were named with explicit terms (e.g., “PTHC,” “pedo,” “Lolita”) indicating child pornography.
Indicted on two counts: (1) receipt of material containing child pornography, 18 U.S.C. § 2252A(a)(2)(B); and (2) possession of an image of child pornography, § 2252A(a)(5)(B). Knowlton had a bench trial, was found guilty on both counts, and was sentenced to concurrent terms (144 and 120 months).
On appeal Knowlton challenged (a) whether the computer files qualified as “material that contains child pornography,” and (b) whether the dates proved at trial materially varied from the indictment’s dates. The Fifth Circuit affirmed and remanded to correct a clerical error in the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether computer files constitute “material that contains child pornography” under § 2252A(a)(2)(B)	Files are a medium/"material" that can contain images; statute and definitions include electronic data capable of conversion to images.	"Material" should be limited to tangible storage units (books, disks, drives); Knowlton’s claim: he received files, not "material that contains" child pornography.	Held: Computer files themselves are "material that contains child pornography" under the statute; conviction affirmed.
Whether the dates of receipt proved at trial materially varied from the indictment (indictment alleged "on or about" Feb 6, 2016–Mar 8, 2016)	Government: "on or about" permits approximation; the evidence showed many files and dates reasonably near the alleged period.	Knowlton: Trial proof established only a few files and some proven dates (e.g., Jan 13, 2016; Nov 29, 2015) that vary from indictment dates.	Held: Variance was not material; "on or about" allows approximate dates and the proven dates were within a reasonable range. Conviction affirmed.

United States v. Woerner, 709 F.3d 527 (5th Cir. 2013) (computer file is a medium capable of containing images of child pornography)
United States v. Roetcisoender, 792 F.3d 547 (5th Cir. 2015) (upholding conviction where computer files constituted the charged material)
United States v. Ross, 948 F.3d 243 (5th Cir. 2020) (affirming convictions involving child‑pornography computer files)
United States v. Winkler, 639 F.3d 692 (5th Cir. 2011) (trial court may infer scope/content from circumstances and file‑naming conventions)
United States v. Tovar, 719 F.3d 376 (5th Cir. 2013) (bench‑trial sufficiency standard: substantial evidence review)
Puckett v. United States, 556 U.S. 129 (2009) (elements of plain‑error review)
United States v. Valdez, 453 F.3d 252 (5th Cir. 2006) ("on or about" permits proof of dates reasonably near the indictment)