Is "any touching" of an underage girl a crime?

"[S]ection 288 . . . require[s] no particular form of physical contact. . . . [T]he crime occurs whenever the trier of fact determines, based on all the circumstances, that an underage child was 'touched' with the requisite sexual intent." (People v. Martinez (1995) 11 Cal.4th 434, 438.) Thus, "section 288 is violated by 'any touching' of an underage child committed with the intent to sexually arouse either the defendant or the child." (People v. Martinez, supra, at p. 442.)