In assessing the seriousness of distribution of invasive images, a targeted distribution to a limited audience (such as the victim's family) may be more insidious and harmful than indiscriminate wide distribution, particularly where the distribution is targeted to the audience most likely to cause harm. Brevity in sentencing remarks on home detention does not of itself indicate error where the relevant considerations have been set out earlier in the remarks. A starting point of five years imprisonment for blackmail involving threats to distribute sexually explicit images to coerce sexual activity, combined with actual distribution, was within the range reasonably open.
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