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Manga artists and anime directors have argued that it is dangerous to try to define child pornography when it comes to artwork , drawings , and animation when regarding hentai due to it being highly ambiguous , and have cited freedom of expression to prevent it from being abused. For example, they argued that even in the anime and manga series Doraemon , the scene of the schoolgirl Shizuka Minamoto taking a bath might be mis-construed as "child pornography". Under Article 7, it outlawed the production, transport, import and export of child pornography, as well as possession of child pornography for the aforementioned purposes. Previously, obscenity was regulated by the Penal Code of Japan. Article of the code has been applied to underage obscenity, notably in a case where a burusera shop owner was arrested on suspicion of possession for sale of obscene media, after he had invited a high school student to appear in a pornographic video.

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