I'm thinking that if they called the place up inside a skirt, or even down inside the pants, a private place, then a person could reasonably be expected not to be photographed there.
So, if you wear a bikini on the subway, it's fine to take a picture of that. If you wear a dress, now it's illegal. Sure, that sounds reasonable and easily enforceable. Already a crime to reach into someone's pants or skirt, and reasonable and easy to enforce. This wouldn't be. Is it a crime if a woman lifts her skirt up and laughs to her friends and a stranger takes a picture, or only if he has to expend thought or effort to take the picture. Shoecam illegal, but google glass record of what his eyes could see anyway legal?
It's a @#%^ing quagmire. "This makes me uncomfortable" shouldn't be the standard for criminalizing behaviour.
To make a long story short, I don't take any responsibility for anything I post here. It's not news, it's not truth, it's not serious. It's parody. It's satire. It's bitter. It's angsty. Your mother's a whore. You like to jack off dogs. That's right, you heard me. You like to grab that dog by the bone and rub it like a ski pole. Your dad? Gay. Your priest? Straight. @#%^ off and let me post. It's not true, it's all in good fun. Now go away.