USSG § 2G2.2(b)(2)(B) Enhancement Upheld

U.S. v. Oldham, 2006 WL 1174508 (5/4/06) - The defendant had a sufficient expectation that he would receive child porn in exchange for displaying child porn on his chat room site to warrant a five level adjustment under USSG § 2G2.2(b)(2)(B), which applies when the defendant has an "expectation" that he will receive a thing of value in exchange for the child porn. A quid pro quo agreement is not necessary.