In People v. Massicot (2002) 97 Cal.App.4th 920, the court considered what parts of the body are included within 'person' and 'private parts' as those words are used within section 314. Massicot was convicted of two counts of indecent exposure with prior convictions for the same offense (sdegreess 314, subd. 1). He had appeared before a woman wearing women's flesh-colored lace underpants and a lace bra. He then turned around and showed her his buttocks, which were revealed by the underpants he was wearing. He did not expose his penis; the underpants covered his genital area and the woman could not see the penis through them, although she could see a 'bulge.' (Massicot, at pp. 922-923.) Prior to trial, Massicot conceded the sexual intent element would not be in issue at trial, agreeing that his conduct toward the woman was for his own sexual arousal. After the evidentiary portion of the trial concluded, the trial court permitted the prosecutor to argue to the jury that a violation of section 314, subdivision 1, did not require total nudity and that Masasicot's partial nudity without genital exposure would meet the exposure element of the statute. (Massicot, at pp. 923-924 and fn. 2.) The Court of Appeal reversed the ensuing conviction for indecent exposure, agreeing with Massicot that his conviction was not supported by substantial evidence 'because Massicot did not display his naked genitals' and because 'the specific intent to expose one's genitals in this manner is an essential element of the indecent exposure offense.' (Massicot, at pp. 922.) In summary, the Massicot court added, 'Because we hold the only reasonable construction of the phrase 'exposes his person' within section 314 is that it means the display of a person's entirely unclothed body, including by necessity the bare genitals, we conclude the premise is correct and Massicot's convictions under section 314, subdivision 1 must be reversed.' (Massicot, at p. 924.)