Is there any case law where a defendant has been found guilty of indecently assaulting a child without the need to grab the child by the arm and hold the crying victim to the ground?

"More particularly, it has been noted that [this approach] fails to recognize a ' defendant may fondle a child's genitals without having to grab the child by the arm and hold the crying victim in order to accomplish the act. Likewise, an assailant may achieve oral copulation without having to grab the victim's head to prevent the victim from resisting.' [Citation.] Lewd conduct of this sort is punishable in and of itself. ( 288, subd. (a).) Therefore, it stands to reason that the force requirement will be deemed satisfied when the defendant uses any force that is 'different from and in excess of the type of force which is used in accomplishing similar lewd acts with a victim's consent.' [Citation.]" (People v. Alvarez, supra, 178 Cal.App.4th at pp. 1004-1005.)