jayeff

I believe the requirement to show the documents without obfuscation is implicit, not only because the DOJ rejected the suggestion about blacking out some of the information, but because if anyone asks to see a document without commenting that it may be censored, we would not normally anticipate that they will be satisfied with one that is censored. In this case particularly, where the whole point of the identification is for the DOJ to be able to confirm the age of a performer (and in several places they have commented that they expect to be able to do their job as easily as possible), it is a major stretch to believe otherwise.

In any case, given the severity of the penalty for being in breach of the new regulations, surely we should be asking what the regulations specifically say we can do, rather than asking where they fail to be specific about what we cannot. Anyone who attempts to push the envelope is risking the cost of a defense and the chance of having that defense rejected.

Actually for content producers, I think the issue is even more basic and pragmatic: what are your customers going to expect? Unless you are US-based, you don't actually have to comply at all. But if you are not compliant with the strictest interpretation of the rules, you will lose some business. Your decisions need to be primarily based on what you believe they will cost you.