Whether the definition of 'sexually explicit conduct' in federal child pornography statutes turns on objective characteristics of the depicted images or the subjective intent of the photographer

is of exceptional importance. The panel majority ignored the clear command of the statutory text: “sexually explicit conduct” turns on characteristics of the conduct depicted in the images or videos and not on the photographer’s subjective sensibilities. The issue is consequential. Every year, federal courts sentence close to 2,000 defendants for offenses incorporating the relevant definition of “sexually explicit conduct.” U.S. Sent’g Comm’n, Federal Sentencing of Child Pornography: Production Offenses 17 (2021). And sentences for this category of offense are severe. Mr. Donoho was sentenced to over 17 years of imprisonment— and his sentence is no aberration. 4. A 14-day extension of time within which to file a certiorari petition is reasonable and necessary. a. Additional time is needed because undersigned counsel was only recently