In 2002, Ashcroft v. Free Speech Coalition held that the possession, creation, or distribution of “virtual child pornography,” pornography created entirely through computer graphics, was not a punishable offense because regualtion impermissibly infringed on the First Amendment right to free speech and did not harm real children. Only a few years after that decision, however, the Court’s wisdom is being put to the test. A virtual world called Second Life, coupled with motion sensing technology, may provide a means for child pornographers to exploit real children while escaping detection. Second Life also provides a forum where users actively engage in sexual conduct with what appears to be a child. Thus, the Free Speech Coalition Court too narrowly construed “harm to a real child” and failed to render a decision that would keep pace with evolving technology.