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This new set of regulations is nothing but an end run around the courts not allowing assaults on the first amendment. This does not place anyone except the porn industry at risk, DO not expect the ACLU or any other white nights to help.
Do expect prosecutions because this is a strict liability statute. As stated above if your records are bad even if the model is 50 years old you will go to jail.
Keeping the records for any website that updates it's content is going to be a nightmare. The heavy burden will be on the publisher of the website not the provider of content unless the primary producer also needs to maintain records of every URL and date of production of images used.
I doubt many sites with dynamic content will be able to live with these rules without considerable new expenses for record keeping.
This one might actually be the right thing for chicken little to scream about.
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