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Similar groups also emerged in the United Kingdom, including legislatively focused groups such as Campaign Against Pornography and Campaign Against Pornography and Censorship , as well as groups associated with radical feminism such as Women Against Violence Against Women and its direct action offshoot Angry Women. In Butler the Court held that Canadian obscenity law violated Canadian citizens' rights to free speech under the Canadian Charter of Rights and Freedoms if enforced on grounds of morality or community standards of decency; but that obscenity law could be enforced constitutionally against some pornography on the basis of the Charter's guarantees of sex equality. However, some feminists tend not to make a distinction between pornography and erotica, and those who have addressed the distinction made by Steinem and others find it problematic. Short summary by counsel in case, Legal Momentum. Valerie Webber in her article "Shades of Gay:


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