What is the test for sexual assault under section 288(a) of the California Penal Code?

Penal Code section 288(a) has two elements: (a) the touching of an underage child's body (b) with a sexual intent. (People v. Martinez (1995) 11 Cal.4th 434, 444.) "However, the form, manner, or nature of the offending act is not otherwise restricted. Conviction under the statute has never depended upon contact with the bare skin or 'private parts' of the defendant or the victim." (Ibid.) That is, "a lewd or lascivious act can occur through the victim's clothing and can involve 'any part' of the victim's body." (Ibid.) Any touching of an underage child committed for purpose of sexual arousal is "lewd or lascivious," and satisfies the statutory requirement. (Id. at pp. 444-446, 452.)