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This Note argues that the IJ, the BIA, and the circuit courts got it wrong. The courts reject creating a category representing young women in fear of being forced into prostitution because they feel it is too broad and does not establish a common characteristic. However, due to the courts' analyses' inconsistencies with the initiatives of the United Nations ("UN") and the United States to prevent and put an end to sex trafficking, a new analysis should be conducted to fulfill this goal.



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