Obstacles encountered in attempts to regulate pornography through the current statutes and ordinances have caused prosecutors to seek new methods for prosecuting pornographers. Several cases highlight the use of this approach. These cases involved live sex shows in public theaters and the pornographic depiction of actual sex acts in publications or movies. In Oregon v. Kravitz, the defendant offered customers in the theater's audience money to engage in sex acts with a female dancer. The theater's manager was prosecuted under the State statute for promoting prostitution. On appeal, the Oregon Court of Appeals upheld the conviction. A similar case in California, People v. Maita, was also upheld by the California Court of Appeals. Additional cases, such as People v. Fixler (California), People v. Kovner (New York), and People v. Souter (California), which were successfully concluded, involved the prosecution of photographers, producers, and distributors of pornography. Prosecuting pornographers under prostitution statues is a method that condemns the underlying criminal conduct and not the finished pornographic material. Prosecution under prostitution statutes is constitutional because there is no violation of due process rights, and any infringement on freedom of expression is justified by the State's interest in regulating prostitution and pornography.