Quote: Freeman says nothing about it needing to be a movie for commercial distribution. The court viewed Freeman's conviction as "a somewhat transparent attempt at an 'end run' around the First Amendment and the state obscenity laws". Last I heard the First Amendment was an individual right, so it is inherantly permissible to do anything for a private film that you could do for a commercial film.
As I said I'm not a lawye, but I know it needs to be a commercial product. If it doesn't have to be, every escort agency would stay that they are just booking their girls for private shoots to all their johns. I don't think that is a valid loophole.