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steffie

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#1

Our 2257 Regs, please Read

06-05-2005, 12:32 PM

Dear Affiliate and Webmaster

With the new 2257 we have made some changes. So please read carefully

1, Each of our Hosted Galleries now state
"18 U.S.C. 2257 Record-Keeping Requirements Compliance Statement" and are linked to our 2257 Regulation. We started this 6 month ago and all Galleries out there, should already have the statement online

2, If you are using our content to promote any sites. We had to take a mandatory step to comply. It's simple so don't freak out. You need to email us the URL of the Main domain and page where you are displaying our pictures. (for instance - abc.com/steffie.htm) Once we receive this information we will add you into our Database. I need to have this in order to comply with the new 2257.

3, If you are building your own Galleries with our Content YOU MUST ad the statement "18 U.S.C. 2257 Record-Keeping Requirements Compliance Statement" and link it to http://www.mad4cash.com/2257.htm. IT MUST BE ON ALL OF THE GALLERIES YOU ARE BUILDING!

4, Non Nude, Soft Core and Non Explicit content is excempt from the 2257 statement, and within the next month we will offer a large variety of such. However just to be on the safe side we require that anybody using our content to build Galleries is now required to ad the 2257 statement and send us a link to the Gallery

5, Our Attorney has promised to rewrite our 2257 statement in such a manner that there are no loopholes and the updated 2257 statement will be up before the due date!

6, If you have Promo Content inside your Members Area from me, and do not want to link outside your protected area, but list it under Secondary Producer on your 2257. Please contact me and I will email you this information ASAP

7, If you have done shoots with me and missing or lost the copy of my ID, please also email me so I can send you and updated copy of my ID

This is the latest information I have received from our Attorney on Friday. He is still reading more up about this issue. Should there be other changes we will let you know

Regards
Steffie
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cyber_ninja

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#2

06-05-2005, 12:32 PM

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#3

06-05-2005, 12:34 PM

Originally posted by steffie

3, If you are building your own Galleries with our Content YOU MUST ad the statement "18 U.S.C. 2257 Record-Keeping Requirements Compliance Statement" and link it to http://www.mad4cash.com/2257.htm. IT MUST BE ON ALL OF THE GALLERIES YOU ARE BUILDING!

So, you want them to link to your 2257 disclosure page?

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Sly

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#4

06-05-2005, 12:34 PM

Several of your points are totally different from what Lightspeed posted earlier. I'm not saying either of you are specifically wrong, I'm just pointing that out. This is going to get reeaally interesting...

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steffie

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#5

06-05-2005, 12:45 PM

I met with my attorney on the 1st to discuss this issue. On Friday I had my second meeting with him. That's what he told me to do and post. He told me that he will read more up about it. We hired him in 1999 when we needed an Internet Attorney really desperatly.
Some of our content was shot before July 1995 and is excempt. We didn't even offer any Partner Programs until recently. So my first instinct was to call Zack (my Atty) about 6 month ago. But now the law is a reality. We are not sending anybody copies of the ID"s of our models either. However, I have been online myself for almost 9 years, have done photoshoots with other Amateurs and I have no problem giving this information to others I done shoots with . Most already have a copy of my ID, some might be old from years ago and need to be updated.

The tricky part with everything and where Attorneys are driving each other out of space is the process with the secondary producer. That's why we need the url of where the gallery you build will be. I have to keep a database on each model where they are. For instance, if you use our content you email me where the gallery is abc.com/steffie.htm. You than email it to me and I will add it under the models name - Chelsea - yourdoman.com/chelsea.htm

But again, I have another meeting with Zack. This is the information I received so far from him.

I am so hating this stuff

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#6

06-05-2005, 12:56 PM

To me, even if it is shot after 1995, you now still need the ID's.

"sexually explicit conduct made after July 3, 1995, and produced, manufactured, published, duplicated, reproduced, or reissued on or after July 3, 1995,"

reissued, published, after 1995. Each time you put it online you publish it. At least that is how I take it.

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steffie

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#7

06-05-2005, 12:56 PM

I just read Steve's Regs, its not that different. Just with the Galleries and the link to our 2257 if we know where the Gallery is.

You must email me the link to the Gallery you build
I will add it to the Model's Database (for Example Chelsea is located at -- and than enter every site she is on, you gallery, etc etc)
Than the person who builds the Gallery must link to our 2257

However, this is for existing Galleries Affiliates build and Hardcore Promo Content we gave away over the past. All the new free Promo Content is very Vanilla. We didn't want all our Affiliates to take their Promo Content down. So that's how we can cover it.

My english isn't the greatest sometimes and sometimes I have a hard time making myself clear. If you have other questions you can icq me at 18314311

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steffie

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#8

06-05-2005, 12:57 PM

Originally posted by TheDoc

To me, even if it is shot after 1995, you now still need the ID's.

"sexually explicit conduct made after July 3, 1995, and produced, manufactured, published, duplicated, reproduced, or reissued on or after July 3, 1995,"

reissued, published, after 1995. Each time you put it online you publish it. At least that is how I take it.

All content shot after 1995 has a model release and copy of ID. We however have shot since 1993 and have pictures online shot between 93 and 95, these are the only once excempt.

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#9

06-05-2005, 12:59 PM

I think your US affiliates are going to be in a world of hurt if they follow your advice here......
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#10

06-05-2005, 12:59 PM

Originally posted by cyber_ninja

click my sig

Wow... I was told you were an idiot and I didn't believe it. I guess I should listen to people more often

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basschick

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#11

06-05-2005, 01:06 PM

steffie - have YOU read the new 2257 regs? they are actually mostly very clear. your affiliates who use your content can NOT link to your 2257 page, or they risk jail. they have to be the custodian of records for the content on their sites - you can't do it for them.

maybe it's time to get serious - since people are risking jail, and some will believe you. pay lawrence walters, clyde dewitt or one of the other attorneys who specialize in our industry.

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#12

06-05-2005, 01:10 PM

Originally posted by BoyAlley

I think your US affiliates are going to be in a world of hurt if they follow your advice here......

This shit is gonna be baaaaad. People get advice from lawyers and are still illegal?

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chadglni

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#13

06-05-2005, 01:13 PM

Originally posted by steffie

We are not sending anybody copies of the ID"s of our models either.

If you give someone content with no ID's you are breaking the law. They are too if they are in the US. That's just one point that is wrong out of several.

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#14

06-05-2005, 01:14 PM

Originally posted by Sly

Several of your points are totally different from what Lightspeed posted earlier. I'm not saying either of you are specifically wrong, I'm just pointing that out. This is going to get reeaally interesting...

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#15

06-05-2005, 01:23 PM

Originally posted by chadglni

If you give someone content with no ID's you are breaking the law. They are too if they are in the US. That's just one point that is wrong out of several.

You are not brakeing the 2257 if you give out content with no ID's. 2257 does not force you to give out the ID's it only forces anyone wanting to use the content legaly inside the US boarders to have it if they want to use it.

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latinasojourn

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#16

06-05-2005, 01:34 PM

lots of horseshit in this thread.

you folks (and your attorney) needs to read the law.
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steffie

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#17

06-05-2005, 01:34 PM

Originally posted by chadglni

If you give someone content with no ID's you are breaking the law. They are too if they are in the US. That's just one point that is wrong out of several.

Hardcore and Sexual Explicit Content only. Vanilla is excempt. Non Nude, Bikini, etc. There is a fine line..

Right now we are not offering any content until Zack gets back to us. For hardcore content out there already we have to have the URL if they want to keep it after June 23rd. So we can ad them to the Girls Database.

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#18

06-05-2005, 01:40 PM

sorry. btw. what I posted was not corect ! I retract my post. It's not quiet that simple.

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steffie

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#19

06-05-2005, 01:46 PM

Look
I am not an Attorney. I have one. We made an appointment. He got a copy of the new law and got back to us a few days later. I only had a few questions for him

1, How do I conform
2, What do I do with the Content out there already, not hosted by me
3, What about Content we are giving out
4, What about hosted Galleries/Videos etc
5, Do I need to rewrite my 2257

How much will this cost me

Once I got the answers I posted them. Maybe I didn't make myself very clear (expecially the once with linking to our 2257). We have another meeting next week. Than I know a lot more.

My biggest concern was all those people who had my hardcore promo content in their Members Area or free area. I wanted to be covered with those without sending my ID.

His advice
1, Send them your ID and Model Release
2, or compile a database where you keep the URL with the Girl Name (me) and page the content is on. Than have them link either directly into your 2257 or into their 2257 where they would have to display your Name and Address as primary Producer

For right now like I said before we suspended all new content until we receive a 100% ok from Zack. But I have had emails regarding my Hardcore Content so I posted what we found out so far.

As to hiring the above mentioned attornies.. We tried month ago, however talk about backed up..

You think it frustrating for you guys, try to be on our site here. I don't have a problem with 2257.. Its the secondary Publisher part which gives everybody a headage. It wouldn't surprise me if their is going to be some sort of addendum regarding it in the future.

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steffie

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#20

06-05-2005, 02:02 PM

So, ok, I got my ass wooped over the past hour. Somebody is refering me to another attorney. Guess mine did his job for me in 1999 but is incompetent when it comes to this

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#21

06-05-2005, 02:10 PM

Originally posted by steffie

Dear Affiliate and Webmaster

With the new 2257 we have made some changes. So please read carefully

3, If you are building your own Galleries with our Content YOU MUST ad the statement "18 U.S.C. 2257 Record-Keeping Requirements Compliance Statement" and link it to http://www.mad4cash.com/2257.htm. IT MUST BE ON ALL OF THE GALLERIES YOU ARE BUILDING!

This is not compliant. A webmaster has to have HIS own 2257 page with HIS name and address. And HE has the have a copy of the Model IDs. Otherwise he is not incompliance. And if you allow him to use YOUR content and you refuse to give him the docs YOU are also not in comliance. You really need to read the regs again. No offense
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#22

06-05-2005, 02:11 PM

Originally posted by steffie

So, ok, I got my ass wooped over the past hour. Somebody is refering me to another attorney. Guess mine did his job for me in 1999 but is incompetent when it comes to this

He may just not be upto date on everything. Print out this thread and fax it to him. We'll bring him up to speed real quick.
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steffie

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#23

06-05-2005, 02:21 PM

I think I am just frustrated. When all that 2257 stuff came about a few years ago we hired him and he did a great job. Of course we went back to him with the new 2257. Now it seems I am getting bad advise.

Our main concern is the secondary part. not primary publisher. Which is easy.

All that stuff we did since 1996. Incorporate, Get Office, Retain Atty.. etc etc blah blah.. Now were back to square one. I have content online floating around since 1996. hell I don't know where it is.

In 96 you just send a Promo Pack to a Website and bang, you got some in return traffic or their Promo Pack. A lot of those sites are no longer around, but there are still people who have my promo packs.

Than we started Partner Programs, now another curve ball. To top it all off I hear today I got bad advice

Trust me, youre not the only once who beat me up. Some of my friends on IcQ told me literally that I am braindead if I stay with Zack.

Maybe I should go and get drunk.. eh?

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#24

06-05-2005, 02:25 PM

Originally posted by steffie

So, ok, I got my ass wooped over the past hour. Somebody is refering me to another attorney. Guess mine did his job for me in 1999 but is incompetent when it comes to this

We aren't trying to woop your ass, just letting you know that attorney either didn't read everything, doesn't care, or doesn't understand. You can't let affiliates link to your d/b because they have to have the documents on hand the same as you. If you don't give them documents you are breaking the law. If you don't want to give out ID's the only thing you can do is tell everyone to remove all explicit images of you.

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chadglni

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#25

06-05-2005, 02:28 PM

You seem to be worried about those that have your content already. I don't think that has anything to do with you if they "choose" to break the law by leaving it up. They are supposed to ask you for the new documentation required at which point you could tell them to remove the content. I'd check on that with a lawyer if that is what you or worried about, I don't think you are required to give out the documents on old stuff if you tell them to take it down. I could be wrong but if that was the case anyone that has given out content ever will be illegal on June 23rd.

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steffie

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#26

06-05-2005, 02:54 PM

Originally posted by chadglni

You seem to be worried about those that have your content already. I don't think that has anything to do with you if they "choose" to break the law by leaving it up. They are supposed to ask you for the new documentation required at which point you could tell them to remove the content. I'd check on that with a lawyer if that is what you or worried about, I don't think you are required to give out the documents on old stuff if you tell them to take it down. I could be wrong but if that was the case anyone that has given out content ever will be illegal on June 23rd.

That is basically the only thing we are worried about. We have years online, tons and tons of Hardcore (That's all I do) I know what to do starting June 23rd and Zack was VERY upfront with that. But when asked what should I do with all that stuff floating around, that's when he came up with this (I know now) hair storming idea. We will still give out Promo content after June 23rd (with ID etc) to Webmasters I have met and got to know over the years and don't worry about those guys stalking me etc...

I have been emailing a lot of website owners I knew had my Promo Package and only heard back from 1. Its a bit frustrating. We want to comply and conform and whatever else we need to do. But Geez. It's starting to get to me. It's not helping that I am getting bad advice.

I really hope they do not go thru with the Retro Active part. and start fresh on June 23rd. If it is Retro Active Oh Lord! So I am trying to play catchup now, just in case it is Retro Active for sure

yikes

Last edited by steffie; 06-05-2005, 02:56 PM.

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#27

06-05-2005, 03:52 PM

Originally posted by steffie

That is basically the only thing we are worried about. We have years online, tons and tons of Hardcore (That's all I do) I know what to do starting June 23rd and Zack was VERY upfront with that. But when asked what should I do with all that stuff floating around, that's when he came up with this (I know now) hair storming idea. We will still give out Promo content after June 23rd (with ID etc) to Webmasters I have met and got to know over the years and don't worry about those guys stalking me etc...

I have been emailing a lot of website owners I knew had my Promo Package and only heard back from 1. Its a bit frustrating. We want to comply and conform and whatever else we need to do. But Geez. It's starting to get to me. It's not helping that I am getting bad advice.

I really hope they do not go thru with the Retro Active part. and start fresh on June 23rd. If it is Retro Active Oh Lord! So I am trying to play catchup now, just in case it is Retro Active for sure

yikes

Not sure if you are getting bad advice or not.

You are trying and according to my lawyer, it is a wait game for a couple of weeks...with; do they really have the manpower to bust you and everyone on the internet that promotes legal adult porn plus are you telling me everything?

When I told him, I don't promote girls that could pass for 14-16 but are 18 years old or sites that think sexually activity involves the perception of humiliation of a women or men, he just said if this true just print out the TOS and acceptance letter with their 2257 regs and the same goes for buying content.

I guess I got bad advice too, but I still believe there is nothing wrong with porn. C-P is wrong even if it is an illusion just like beating a woman or man for one's sexual satisfaction. Having sex is normal and viewing porn is normal.

I think it is healthy...I wonder how many couples viewed porn on the internet and had the BEST SEX ever since they would never go to a sleazy sex shop to rent a movie but in the privacy of their own home they could. JMO?
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#28

06-05-2005, 05:15 PM

Straight from the new regulations:

One commenter commented that secondary
producers should only be required to retain
on file the contact information for the primary
producers' custodians of records. The Department
declines to adopt these comments. As publishers
of sexually explicit material, secondary producers
are equally responsible for protecting minors from
exploitation as the primary producers who
photograph sexually explicit acts.

Read them yourself here. It is the last paragraph on page 29612, continuing onto page 29613.

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