Obscene material that could result in a fine must have “prurient interests” lacking “literary, artistic, political or scientific merit” as defined by “the average person.” Premium channels tried to lure viewers from network TV and basic cable with nudity.

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And even the most innocent sitcoms will offer viewers a glimpse into the characters’ love lives with familiar tropes—the kids walking in; the attempt to not be a “boring couple” with sexual misadventures; the makeup sex after a fight.

But many new shows use the bedroom as an integral storytelling vehicle rather than a cheap trick to spice up the plot.

, Lena Dunham’s Hannah Horvath submits herself to awkward, humiliating and—for some—realistic sex.

Her friend with benefits, Adam (Adam Driver), takes charge of the encounter and won’t even answer the question of whether he’s putting on a condom.

If showing a man give a woman oral pleasure is rare, the 69 is the unicorn of TV sex.

The first question the director of the episode, Thomas Schlamme, asked was how they would position the actors.

But the married-couple sex scene most widely praised by critics in the last several years was one between Elizabeth (Keri Russell) and Philip (Matthew Rhys) Jennings, Russian spies masquerading as American suburbanites on FX’s .

Showrunners Joel Fields and Joe Weisberg began season two sitting in their writers’ room trying to list every single sex position known to man.

Five years after Dunham’s first unsatisfying hookup on infamous 69 scene last season.