United States (1957) the government brief distinguished three classes of sexual material: 'novels of apparently serious literary intent' 'borderline entertainment. 'Borderline pornography' appealed to sexual prurience, but had positive qualities, such as literary or artistic merit, and so was arguably permitted by obscenity laws 'hardcore pornography' lacked such merits and was definitely prohibited.
A distinction between 'hardcore pornography' and 'borderline pornography' (or 'borderline obscenity') was made in the 1950s and 1960s by American jurists discussing obscenity laws.