Porn distributors Robert Zicari and Janet Romano thought they had finally reached an end to their long legal battle when Pittsburgh U.S. District Judge Gary L. Lancaster dismissed a 10-count criminal indictment charging the couple with violating federal obscenity laws, ruling the laws unconstitutional.

However, a three-judge panel of the 3rd U.S. Circuit Court of Appeals overturned the decision in U.S. v. Extreme Associates Inc. on Dec. 12, 2005, holding that the district court had incorrectly interpreted Supreme Court precedents.