In People v. Babcock (1993) 14 Cal.App.4th 383, the defendant grabbed the victims' hands and forced the victims to touch his genitals; when one victim attempted to pull her hand away, the defendant overcame her resistance. ( People v. Babcock, supra, 14 Cal.App.4th at p. 385.) Holding that these acts were substantial evidence of force, the appellate court concluded that the flaw in the analyses found in People v. Schulz and People v. Senior: "is in their improper attempt to merge the lewd acts and the force by which they were accomplished as a matter of law. Unlike the court in Schulz, we do not believe that holding a victim who was trying to escape in a corner is necessarily an element of the lewd act of touching her vagina and breasts. Unlike the court in Senior, we do not believe that pulling a victim back as she tried to get away is necessarily an element of oral copulation. And, unlike the defendant in this case, we do not believe that grabbing the victims' hands and overcoming the resistance of an eight-year-old child are necessarily elements of the lewd acts of touching defendant's crotch." ( People v. Babcock, supra, 14 Cal.App.4th at p. 388.)