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I'm not an attorney, that's for sure! The law is the law; I had hoped my comments to DOJ would give reason for them to not just slam the doors in those instances where they had an option of "slamming" versus the "way/simple-compliance" DOJ could opt into to regulate/enforce the inclusion of Secondary Producers. I thought the law was merely making the term "Producers" include "Secondary Producers", but that it did not specifically spell out cross-referencing, and the other aspects that I think DOJ in the initial 2257 Regulations took liberty in making them overbearing by all the unnecessary admin stuff, and now wants to do likewise to Secondary Producers.
I still think that people on this board need to submit comments claiming that the proposed regs overstep the least restrictive means of including Secondary Producers, and are burdensome. Again, I'm not an attorney. My letter has been seen, however, by Free Speech/1st Amendment attorneys who have not since mentioned what you state here.
Have a great weekend, everybody (and motivate others to stand up and fight the way DOJ is writing the overburdensome regulations implementing the new law--PLEASE!!).
Dave
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