What Was the Major Distinction Between the Ulysses and Lady

What was the major distinction between the Ulysses and Lady Chatterley's Lover cases?

A) The court upheld sexual references in Ulysses as having literary merit but not in Chatterley.
B) One ruling was against the customs service; the other against the postmaster general.
C) Chatterley had literary merit and the explicit love scenes were essential to the heart of the story.
D) One was in Gaelic, the other in English.