Two people have sex under a running shower. Since shower windows have a tendency to get steamed up, this allows for literal Censor Steam. Wall-Bang Her is a possibility, but there is the likelihood of injury from slip and fall (which hardly happens in fiction, unless one was to write a screwball romantic comedy and turn that scene into slapstick). Two-Person Pool Party is similar to this, only it's two people having sex in a bathtub, Jacuzzi, or a pool (public or private -- dealer's choice). Often an example of Hollywood Sex, although Your Mileage May Vary. Examples of Shower of Love include:
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