In United States v. Williams, 553 U.S. 285 (2008), the Supreme Court yet again considered a challenge to a child pornography statute. After the decision in Ashcroft was handed down, Congress passed the Prosecutorial Remedies and Other Tools to end the Exploitation of Children Today Act of 2003 ("the Act"). Id. at 1836. The Act's "pandering and solicitation" provision criminalizes pandering of child pornography, regardless of actual possession. 18 U.S.C. 2252A(a)(3)(B). "Generally speaking, the Act prohibits offers to provide and requests to obtain child pornography. The statute does not require the actual existence of child pornography." Id. at 1838. "Rather than targeting the underlying material, this statute bans the collateral speech that introduces such material into the child-pornography distribution network." Id. at 1838-39. In determining whether the Act criminalized a "substantial amount of protected expressive activity," the Court noted that "offers to engage in illegal transactions are categorically excluded from First Amendment protection." Williams, 128 S. Ct. at 1841. The Court further noted that the presence of a scienter requirement in the Act served to remedy potential overbreadth: "a crime is committed only when the speaker believes or intends the listener to believe that the subject of the proposed transaction depicts real children." Id. at 1844. Based on these reasons, the Court held that "offers to provide or requests to obtain child pornography are categorically excluded from the First Amendment," and the Act is thereby constitutional. Id. at 1842.