How have courts interpreted the definition of "violence" in the context of sexual assault?

the person of another.' [Citation.]" (People v. Colantuono (1994) 7 Cal.4th 206, 214, italics added.) "One may commit an assault without making actual physical contact with the person of the victim." (People v. Aguilar (1997) 16 Cal.4th 1023, 1028.) "The terms 'violence' and 'force' are synonymous when used in relation to assault [citation], and include any application of force even though it entails no pain or bodily harm and leaves no mark. As stated in People v. Bradbury [(1907)] 151 Cal. 675, 677, . . . 'The kind of physical force is immaterial . . . ; it [violence] may consist in the taking of indecent liberties with a woman, or laying hold of and kissing her against her will.' It follows that the taking of indecent liberties with a five-year-old child is an act of violence, and if of the type described and made punishable by section 288 . . . , is 'criminal violence.'" (People v. James (1935) 9 Cal.App.2d 162, 163-164.)