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In some cases, some states have ratified their local state laws for inclusion to prevent California's Freeman decision to be applied to actors who are paid a fee for sexual actions within their state borders. One example is the state of Texas whose prostitution law specifically states:

An offense is established under Subsection (a)(1) whether the actor is to receive or pay a fee. An offense is established under Subsection (a)(2) whether the actor solicits a person to hire him or offers to hire the person solicited.[4]

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