I finally just completed the DOJ official release:
http://a257.g.akamaitech.net/7/257/2...5/05-10107.htm
It's a loooong read, but they answered/rebutted alot of comments that people sent in.
Lots of things for the industry lawyers to be picking through. I found this comment to shed light on the mindset of the authors of the document pertaining to the adult biz:
To put this into context, they were addressing the issue of no 3rd party custodian of records, and how it was a bad idea, etc.
"Historically, producers have used front corporations in order to evade both law enforcement and tax authorities."
(at the end of Page 29614)
But in their own defense, they did listen to the commentors, and they allowed for 2257 info to be placed on a separate page, rather than having all the text fill up on your home page with specific size fonts, colors, etc that was in the draft.
There is no cliff notes to their explanation document and trying to interpret words like "distributor" will only have you rationalizing to a false sense of comprehension.
And in other areas, they were quite clear about how all of this is done to protect children from being exploited (which is a very noble cause).. which is why we know they won't be asking for 2257 info on MILF material
While the finer details of the new parts should be left up to an attorney, there is alot of practical things you can do, whether a primary or secondary producer as i posted up above.
Additional 2257 background info at JD's website:
http://www.xxxlaw.net/
Fight the too many words!