The Federal Protection of Children Against Sexual Exploitation Act was passed in 1984, amending the 1977 law by protecting anyone under age 18 and removing the requirement that monetary gain be involved in the pornography. States have passed similar laws. Courts have held that the 1984 law could not be applied to an act occurring before it took effect and that photo processors were not covered by the Federal law. However, Peter McCue was convicted under a Pennsylvania law which forbade transferring pornographic materials involving minors. The appellate court noted that the law excluded purely personal use of pornographic material or noncommercial exchange, but that McCue had transferred or intended to transfer the child pornography in his possession. These cases show the need for specificity and also raise the question of how people outside the minor's immediate family are able to accomplish their deeds without the knowledge or consent of the parents. 18 footnotes