United States v. Williams, 2011 U.S. App. LEXIS 21743

Williams posted and shared over 5,000 images of prepubescent children engaging in sexually explicit conduct using peer-to-peer software.
FBI agents identified Williams as the owner and obtained a search warrant of his mobile home.
Items found included x-rays of young boys' genitalia, a guide on interacting with boys, and boys' clothing/articles.
Williams admitted using internet networks to view and share child pornography.
A grand jury indicted Williams for possession (§2252A(a)(5)(B)), distribution (§2252A(a)(2)(B)), and advertising distribution (§2251(d)(1)(A)); the district court denied the motion to dismiss the advertising charge.
Williams entered a conditional guilty plea with the remaining charges dismissed and reserved appeal on the §2251(d)(1)(A) issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 2251(d)(1)(A) requires personal production.	Williams argues personal production is required.	Williams asserts the statute targets ads for production by others; no production by advertiser is needed.	No personal production required; plain text supports liability for advertising/ distribution.

United States v. Christie, 624 F.3d 558 (3d Cir. 2010) (conviction upheld for online distribution without personal production)
United States v. Sewell, 513 F.3d 820 (8th Cir. 2008) (advertising distribution without personal production sustains conviction)
United States v. Rowe, 414 F.3d 271 (2d Cir. 2005) (chat-room posting sufficient for § 2251(a)/(d))
United States v. Shaffer, 472 F.3d 1219 (10th Cir. 2007) (distribution via shared network storage satisfied § 2251 elements)
In re Gruntz, 202 F.3d 1074 (9th Cir. 2000) (rejects inserting nonstatutory production requirements)