Does creating a visual depiction of sexual conduct of a minor need to be the dominant or specific purpose; one of the dominant or specific purposes; or is it enough that it occurs at all (one of infinite purposes)?

QUESTION(S) PRESENTED la. Does creating a visual depiction of sexual conduct of a minor need to be the dominant or specific purpose; one of the dominant or specific purposes; or is it enough that it occurs at all (one of infinite purposes)? 1b. Has the mens rea or specific intent element of 18 U.S.C. 2251 been interpreted too broadly to include impulsive or inadvertent acts rather than only those acts for which the actor possessed criminal intent or a dominant purpose of committing the forbidden act? 1c. What is the illegal or forbidden act under 18 U.S.C. 2251(a)? Is it illegal to make a visual depiction of a minor engaged in sexually explicit conduct; or is it illegal to engage the minor in sexually explicit conduct because one plans or wants to create a visual depiction of that conduct? , 2a. When is specific intent established for the purpose of 18 U.S.C. 2251? Does it need to exist. at the onset of the sexual conduct or can it exist as a result of the sexual conduct after such conduct has begun? 2b. If specific intent must be established for the purpose of 18 U.S.C. 2251 at the start or onset of sexual conduct, what constitutes the start of sexual conduct? 3. Is 18 U.S.C. 2251 unconstitutionally vague and therefore in violation of the vagueness doctrine due to its oddly written and confusing language as well as the use of the word "uses" which has led to arbitrary prosecutions due to the legislatures delegation of authority to judges being so extensive? 4. Is a person "used" for the purpose of 18 U.S.C. 2251{a) if they are photographed or videotaped? 5. Is jury instruction #15 too confusing? Specifically element 3 which is supposed to place intent on the purpose for engaging a minor in sexual conduct, but appears to place intent on whether or not the visual depiction was created purposefully? 6. Is 18 U.S.C. 2251 unconstitutional as applied to Mr. Fortier because his case solely involved intrastate conduct using an iPhone which was not purchased for the purpose of creating pornography, rendering its prohibition an unconstitutional Page 1 of 2 . Don. extension of the Commerce Clause? 7. As the use of cellular devices with cameras and the propensity for those using them to frequently and impulsively record everyday happenings grows, will the current interpretation of 18 U.S.C. 2251 make anyone, including those in high school or college who are under the age of 18 or in a legal romantic or sexual relationship with someone under the age of 18, criminally responsible and subject to a federal sentence of 15-30 years or more anytime they photograph or videotape themselves or those individuals under the age of 18 they are involved with engaging . . in sexual conduct? ; or is 18 U.S.C. 225lenforced unfairly and purposed only for certain individuals and if so, what type of discrimination is used to decide who is held criminally responsible and who is immune to the statute? Also, with whom does this critical decision lie? Page 2 of 2