th Cir. 2004) 30 United States v. Yousef, 327 F.3d 56 (2d Cir. 2003) 6, 8 Yates v. State, 171 S.W.3d 215 (Tex. App. 2005) 17 Other Authorities Bennett & O'Donohue, "The Construct of Grooming in Child Sexual Abuse, 23 J. Child Sexual Abuse 957 (2014) 10 Craven et al., "Sexual grooming of children," 12 J. Sexu

wed professional literature in 1984, the term `grooming' has become so widely adopted that it will remain in widespread use for decades to come."); Bennett & O'Donohue, "The Construct of Grooming in Child Sexual Abuse: Conceptual and Measurement Issues," 23 J. Child Sexual Abuse 957, 964-68 (2014) (reviewing the li

monalities. Can't give a test. o Interrater reliability — whether or not separate individuals agree on how to code behaviors o Does not agree with Bennett & O'Donohue opinion about whether grooming should be used in forensic settings. • In such settings, does not take anything at face value but can apply groomin

t al., 2009; Marshall et al., 2015). Additionally, literature has identified that some offenders may provide the child with drugs or alcohol (e.g., Bennett & O'Donohue, 2014), which would be most commonly used with older victims. Desensitizing the child to sexual content and physical contact Fourth, there appears