A 10% discount for the utilitarian value of a guilty plea entered on the first day of trial remains appropriate for Commonwealth offences following Xiao v R. The factors identified in DPP (Cth) v Beattie for assessing objective seriousness of offences under ss 272.8 and 272.9 of the Criminal Code 1995 (Cth) apply equally to offences under ss 272.11 and 272.14. Remote sexual exploitation of children via webcam and internet communications does not materially lessen the gravity of the offending.
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