From Haynes v. Alfred A. Knopf, Inc. (7th Cir. 1993) (Posner, J.):
Entering one’s bedroom with a bottle in one hand and a cigarette in the other is not foreplay.
For those who for some reason want context, the issue was whether a book improperly invaded plaintiff’s privacy; the court suggested that plaintiffs might have prevailed if defendants had given “intimate details of [their] sexual acts,” but concluded that the particular detail described in the quote didn’t qualify.