court filing or legal brief: Case 1:20-cr-00830-PAE Document 178 Filed 03/27/24 Page 16 of 26

The document argues that the PROTECT Act's amendment to 18 U.S.C. § 3283 applies to the defendant's conduct, even though it occurred before the amendment was enacted, because the statutory text clearly intends to extend the time to bring charges for pre-enactment conduct.