The Court identified 13 factors relevant to assessing the objective seriousness of child pornography possession and dissemination/transmission offences, drawing from R v Gent, R v Oliver and other authorities. These include whether actual children were used, the nature and content of the material, the number of images, the offender's purpose, the degree of planning and sophistication, and whether the offender acted alone or in a network. General deterrence and denunciation remain of particular importance in sentencing for these offences, and prior good character is legitimately given less weight. An error as to the maximum penalty for an offence, even in a multi-count sentencing exercise, may infect the overall sentencing discretion and require resentencing.
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