To the Editor:

More than 100 members of Congress (22 senators and 82 representatives) have asked for the right to argue in the United States Court of Appeals for the Third Circuit how the child pornography law should be interpreted in Knox v. United States (news article, Dec. 28). The case involves videotapes of girls 10 to 17 years old wearing bathing suits, leotards or underwear while the camera zoomed in on their covered genitals.

Discussing this case of the twice-convicted child pornographer Stephen A. Knox, Anthony Lewis focuses on whether or not the Federal child pornography law applies in cases when children are not completely nude (column, Nov. 29). The Clinton Administration is charged with reversing a Bush Administration position in this case, thus possibly giving the Supreme Court a reason to let Mr. Knox go free. The Bush Administration convicted him of receiving and possessing sexually exploitive videotapes of partly clad children, citing legislative history that nudity is not a requirement of the Federal law.

Mr. Lewis pays little attention to a more serious charge that the Clinton Administration deliberately reinterpreted a key term in the law under which most child pornography cases involving nude children are prosecuted, "lascivious exhibition." The Administration urged the high court to accept a very narrow interpretation of that term, one never before used by the Justice Department.

The Justice Department argued in its Supreme Court brief that lascivious exhibition of a child's genitals or pubic area (even if nude) violates Federal law "only" if the exhibition is by the child, that is, exhibiting his or her genitals or acting or posing in such a way as to exhibit that area lasciviously. Action of the child, rather than the pornographer, is the key to interpretation of the law, according to the Clinton Justice Department. If that were the case, then most child pornography cases prosecuted by the department could not have been brought, and the number of future cases would be very substantially reduced. Child pornographers often exhibit a child's genitals or pubic area in a lascivious manner, but without compliance or action of the child.