In People v. La Fontaine (1978) 79 Cal. App. 3d 176, the defendant offered the victim a ride, and subsequently stopped his car on the side of a road and asked the victim if he wanted to make "an easy five or ten dollars." When the victim asked how, the defendant replied "I give you a blow job." The victim refused and got out of the car. The defendant never touched the victim or made any movement toward the victim's body. He was charged with an attempt to commit a lewd or lascivious act upon a child. The court of appeal concluded that the defendant's conduct was merely solicitation, and that "acts of solicitation constitute preparation only and do not rise to the level of the offense of a criminal attempt." (Id. at p. 179-180, 183.) The holding in La Fontaine does not represent the law. To the contrary, its reasoning appears not to have gained any following at all, and to have been rejected implicitly or explicitly by virtually all later cases. (for example, People v. Memro (1985) 38 Cal.3d 658)