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Reading the DOJ response to comments from the last round, they do make a reasonable effort to balance the intent of the law, requiring that pornographers keep records, with industry concerns about the details of the process. Reasonable from their point of view, that is.
If you comment, your comments are most likely to be effective if you put yourself in their shoes as regulators and explain how your proposal for a change would make the process work better for the public and for DOJ rather than just whining about how it affects you. To pick a random example, if you were going suggest that they allow records to be held by an industry trade group, you could talk about how that could make it quick and easy for DOJ to check compliance by clicking a link to the trade group site that would include a video ID. Just by clicking the link, the trade group's web site would confirm you did in fact upload documents for that video. That gives them a reason to like the idea of the third party record keeper. That third party might have a database such that you only have to upload the ID once, then just click their name for each of their videos, but in the comments you'd focus on how your suggestion helps enforce the law, how it helps the public and how it makes enforcement of 2257 more efficient.
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