1 United States v. Shaffer, deals with the meaning of distribution. The Court discussed how the gas station distributes gas by making it easy for people to take gas and activity urging them to do so. Does a person who merely has files in a shared folder really send the same invitation? On the other hand, if making images freely available to others was not distributing images, what other way could you hold people liable for hosting websites and the like that included contraband files? 2 Please review United States v. Husmann How would Husmanns insight be applied in practice? Can police just go undercover and access the files if the user is still doing this when they investigate the crime? Explain. Can the feds prosecute the person for attempted distribution under the substantial step test?.