(with reference to goods bought or sold) surreptitiously and typically illegally
(买卖)偷偷地;私下地;非法地
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hard porn is legally banned, but still available under the counter 赤裸裸的淫秽作品是明令禁止的,但仍可私下买到[as modifier]
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an under-the-counter deal 非法交易。