Oh, for sure. I’m talking about laws specifically targeted to minors. “Obscenity” is a catch-all that is well-established, but if you are trying to protect children from abuse, it’s a very blunt instrument and not as effective as targeted abuse and trafficking statutes. The statutory schemes used to outlaw virtual CSAM have failed to my knowledge.
That case was statutorily superseded in part by the PROTECT Act, which attempted to differentiate itself by…relying on an obscenity standard. So it’s a bit illusory that it does anything new.