The first of twenty-three installments of Ulysses appeared in the Little Review in March 1918. Between 1919 and 1920, the US Postal Service confiscated four issues because they violated the Comstock Act, which prohibited the distribution by mail of printed matter deemed obscene. The issue containing an excerpt from the “Nausicaa” episode also provoked a court case against editors Anderson and Heap. In the offending passages, Leopold Bloom masturbates as he watches Gerty McDowell, a young woman who indulges him by leaning back and raising her skirt. Lawyer John Quinn’s defense—essentially, that Ulysses was not obscene since it was unintelligible to average readers—was a misfire. Anderson and Heap were fined, and the novel was banned in the United States.