In an interview in March 2007, Berry said that her toplessness in Swordfish was "gratuitous" to the movie, but that she needed to do so to get over her fear of nudity, and that it was the best thing she did for her career.
Other filmmakers followed suit, particularly in historical dramas such as 1934 — which, among other things, shows topless women being burned at the stake — and contemporary stories filmed in exotic, mostly tropical, locations.
Fordham Law School professor James Cohen said the context of the cover did not suggest pornography.
As the genre developed during the 1960s films began showing scenes of simulated sex.
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