How has the court interpreted the definition of "force" in section 288 of the Criminal Code?

241, fn. 12, the court rejected Senior, stating that, "in light of convincing criticisms set forth in Babcock and Neel, we respectfully disagree with the interpretation of the 'force' requirement of section 288, subdivision (b) discussed in Schulz and Senior. We instead join those courts which have held that '[i]n subdivision (b), the element of force, violence, duress, menace, or fear of immediate and unlawful bodily injury on the victim or another person is intended as a requirement that the lewd act be undertaken without the consent of the victim. [Citation.] As used in that subdivision, "force" means "physical force substantially different from or substantially greater than that necessary to accomplish the lewd act itself."'" (People v. Bolander, supra, 23 Cal.App.4th at pp. 160-161.) Hermosillo used such force.

The judgment is affirmed.