2257 Roll-Call for DOJ Comment Period

off topic, but can you take a look at this dave. you especially i would like to see this.

http://www.gofuckyourself.com/showthread.php?t=761354

Thanks--I Just Responded to it (there)! That could be a busy time what with the DOJ deadline for our comments, this --both are quite important. Thanks.

I hope Secondary Producers see how potentially important this is to their business and personal lives.

Dave

Morning Bump...

Got some free time today?

Check the FSC link and post your comments concerning the impact of the proposed 2257 regs.

Your input counts and is important.

good on yah

I'm going to make my commits again.. However we all know how much difference the commits made the last time. They didn't change anything the DOJ has their mind set on one thing and that how it will be until challenged in the court of law.

Please and Thank You.

If we give them a lot of feedback, they can't say that we don't care and the proposed regs aren't a burden.

Please, take a moment because it's your dollar and your ass that is on the line.

Thank you,

If that not enough motivations, do it because I said "Please" and "Thank you".

My Momma told me to use those words and I would get a lot further in life.

I sent my comments to my lawyer who is submitting them for me. Kinda sad how dead this thread is.

You this THIS thread is dead? I was looking at the DOJ website and how many comments have actually been submitted. It was a SMALL handful of them, and several of those weren't even from US Citizens / Companies but from foreigners.

I'm hoping everyone is just waiting on legal guidance on what they've written, like myself, and we'll soon be seeing a huge flood of comments coming in.

If not, we as an industry are doing a pretty shitty job of helping the attorneys protect OUR livelihoods.

Can you post that DOJ url for us--thanks!

Dave

What is the FSC doing about the adam walsh act?

It is my understanding, it became law that secondary producers had to maintain records under this.

Does the FSC plan to address this as well?

http://www.freespeechcoalition.com/F...view&coid=1073

Sorry I didn't mean the DOJ website I meant the Federal Register. Let me see if I can find a way to get a direct link to the comments, I can only pull it up via searching right now.

I don't believe there's anyway to link to it directly. You have to do a search.

I'll try to walk everyone through it.

1. go to www.Regulations.gov
2. Leave step 1, 3, 4 as is. Under step 2 choose "Department of Justice - All"
3. submit form
4. Look for "DOJ-CRM-2007-0122" Revised Regulations for Records Relating to Visual Depictions of Sexually Explicit Conduct
5. Click on the first link in that row labeled "DOJ-CRM-2007-0122".

That will pull up a directory of all of the comments for you to read through. Current list includes just 22 submissions.

Wait until you read how shitty most of them are, and like I said, several of those aren't even from US individuals/companies.

something I should do when I am sober

Thanks for your fine efforts for us:-))

Dave

Lubbins you long time breeder!

Attention fat, lazy, ugly ass disgusting fucks that run TGPs. In here!

I read some them they arent bad ,they are people who are scared to put their home addresses online which is a good point. Most people arent going to be able to break anything down to man hours or costs.Also probably 90 percent of all webmasters aren't compliant on any level and perform the head in sand technique.To me as an adult producer you should be able to register with the doj.They get you a reg number which has to be posted on your site. That way people dont have to put their home addresses on their sites. I also think the doj really doesnt give a shit how put out we really are at the end of the day.

Background
The U.S. Justice Department is seeking to amend and update the 2257 regulations by a process known as notice-and-comment rulemaking. In this process, the Government publishes proposed regulations in a publication called the Federal Register and invites public comment for a specified period. Then, the Government goes back and considers the comments. It can and usually does change the proposed rules at least slightly. Then it publishes them, also in the Federal Register, as a final rule with an effective date announced when the final rule is published.

So far, the first step in this process occurred on July 12, 2007. You can find the relevant pages of the Federal Register (giving the Justice Department's reasoning and the proposed regulations) on the FSC web site. The next step, the comment period, is NOW.
Here is what you can do . . .

Submit Comments
In their released regulations, the DOJ stated that the cost of industry compliance for 2257 is negligible. It is up to us to convince them otherwise. If we can make a case that 2257 imposes an undue burden to small business or an expense of over $100,000,000 annually to the industry as a whole, the government is under severely increased scrutiny as far as the imposition of these regulations. Financial burdens are only one of the subjects appropriate for comment. You are the expert, make sure you communicate the full extent of the burden 2257 imposes on you and your business. If DOJ disregards our input from the public comment period, at the very least, we will have a much more solid foundation for our next phase of litigation.

What to Submit
It is important communicate the extent of the burden 2257 imposes including any or all of the following:

? Staffing costs to maintain records
? Attorney costs to assure compliance
? Storage expenses
? Additional IT expenses
? If you, or someone you know, have not been able to enter the industry because of the financial burden that 2257 would impose
? Associated costs for 20 hours per week availability for FBI inspections between the hours of 9AM and 5PM and during production
? Cross-referencing and additional information collection and maintenance (required for 7 years)
? The percentage of overall company expenses related to 2257
? For secondary producers the difficulty and expense of obtaining records from primaries
? Other burdens imposed by 2257

(Note: Always strive to be accurate when speaking to the Government. But cost and other burden estimates are okay so long as they are reasonably accurate as forecasts--just as you would do for business planning purposes. It is not necessary or advisable to go into a lot of personally identifiable detail about your record-keeping practices to date.)


How to Submit Comments
FSC would like to make it as easy as possible for adult entertainment industry members to participate. Below are three ways to participate ? select the one that works best for you.

1. FSC will assist you in writing your statement for public comments - Email us at [email protected], tell us about the burdens that 2257 imposes on your business, we will compile your comments into a document ready for submission and send it back to you with instructions on how to submit.
2. Sign on to a statement prepared by FSC representing concerned members of the adult entertainment industry. Email us at [email protected] tell us that you would like to sign on to the 2257 proposed Rules and Regs statement and we will add your name to the list. The statement will be posted on our website by mid August and sent back to you for confirmation prior to submission.
3. Submit your own statement for public comment :
By mail to:
Andrew Oosterbaan
Chief
Child Exploitation and Obscenity Section
Criminal Division, United States Department of Justice
Washington DC 20530
Attn: ?Docket No. CRM 104?

Comments may be submitted electronically to: [email protected] or by using the electronic form provided on the site at www.regulations.gov
Comments submitted electronically must include Docket No. CRM 104 in the subject box.

Please send a copy of your correspondence to:
Free Speech Coalition
2257 Public Comments
PO Box 10480
Canoga Park, CA 91309
or [email protected]

When Are Comments Due?
The public comment period ends September 10, 2007. Please don?t delay.

What is the FSC doing about the adam walsh act?

It is my understanding, it became law that secondary producers had to maintain records under this.

Does the FSC plan to address this as well?

Morning Bump.

Lunch Bump

Posted my comment:

Well I'm definitely not out of shape or run a tgp but I just submitted my comments. Looks like it takes time to show up. Here is a copy:

I would like to comment on the proposed regulations but I would also like to maintain my privacy. Please accept my comments below:

1. The proposed regulations simply will not work. The ones that are producing illegal material simply do not follow laws and they will ignore the law and of course they will not keep records.

2. Secondary producers should not be inspected because they are using content created by a primary producer. Secondary producers should have to list the address of the primary producer. It is much easier to go directly to the source than to sort through thousands, maybe millions of secondary producer sites. This would save time and money on your end.

3. One solution that has come about since making secondary producers responsible is some primary producers and willing to give out document information containing private information of models. This will backfire and leaves the privacy of all models in jeopardy. The documents should remain with the primary producer. They need to be the ones resposible for maintaining the documents.

4. Primary producers must have a sworn statement stating that all of the content is legal and all models are over the age of 18.

5. All content needs to be watermarked to display where the content originated.

6. All hardcore content needs to be behind a members which can be accessed with age verification through a credit card.

7. The display of the business address is particularly disturbing. This will lead to the ultimate loss of privacy. Producers that do work from home will have to spend thousands of dollars per month and year on an office if they want to keep there home address private. They will also have to spend money on possible baby sitters, send children back to school if home schooled, transportation, and meals. Some producers simply cannot afford this burden and it will have a chain effect on the business. If an inspector wants to find the owner of a site, they simply know how. The private address of secondary producers does not need to be displayed on the site.

8. The regulations have no effect on foreign webmasters which will take even more man power to sort through who is residing in the U.S. and who is exempt due to their location. This will lead to a huge loss of business to U.S. webmasters that will be at a serious disadvantage to their foreign competitors. Another loss of income.

9. I personally have seen the effect on my income since switching from using content from trusted primary producers to simple text links with zero content. My income has dropped significantly.

Majority of the adult entertainment industry are resposible adults. We don't like the feeling of being targetted or guilty of crimes that will did not and will not commit. We want to eradicate illegal material online just as much as you do. We should find a way to work together. Better business for us means more tax money for the U.S. Ultimately, primar producers need to be the ones held responsible for the content. Going directly to the source will be much easier, beneficial, and cost effective.

can a guy get an answer?.....


What is the FSC doing about the adam walsh act?

It is my understanding, it became law that secondary producers had to maintain records under this.

Does the FSC plan to address this as well?

Swampthing,

I hope that this position statement will answer you question about the secondary producers, the new proposed regulations and the actions of the FSC in response to the new proposed regulations. I'd like to give you a clearer answer; but, I can only speak for myself.



FSC Statement on 2257 New Regulations

It is important to recognize that the regulations that the Department of Justice has set forth today are simply proposed regulations, issued for comment and possible change.

FSC will extensively comment on the regulations, and we intend to launch an industry-wide campaign to solicit your comments as well. We need your participation in this process. In the coming days we will provide details on how to comment.

Some of the points set forth were expected, and they represent the modest gains that we have achieved through litigation thus far. Some of the other points are troubling and represent the intransigence which we have come to expect from Attorney General Gonzales and his associates.

On the critical subject of secondary producers, the Justice Department is continuing to suggest that it has been right all along and that Congress ALWAYS intended secondary producer to be included in 2257. Therefore they are considering the 1995 regulation to be valid for secondary as well as primary. We understand that for many of you it is simply impossible to comply with the Justice Department?s demands and that is one of the reasons why we will continue the fight.

Unless the final regulations change radically from those proposed today, FSC will continue our litigation at the appropriate place and time, including seeking another injunction for secondary producers as well as others.

At the end day we will make sure that federal judges understand the absurdity of these regulations, and we will not let up on our commitment to you and to your rights.

I have to wonder... in the middle of a key moment in the 2257 discussions, the FSC is off forming an anti-piracy group.

Hello? McFly?

I realized that the piracy problem is out of hand, hurting our members and needs to be addressed. Over the last year, I made several trips to the LA and addressed the issue with many studio owners and national sales managers.

As a result of my input and that of other industry leaders, the FSC has been discussing forming a anti-piracy task force for quite a while. We had the actual vote on its creation at the June 30th board meeting.

When we voted back in June, there was no other organization addressing the problem for the adult industry and it was not a major issue in the forums as it has been recently.

Before making a public statement, we wanted to have our first task force meeting and be sure we had a plan in place...hence, this last week's statement.

I hope this addresses your concerns.

Thanks for the response, I think Im pretty much schooled up on the 2257 issue, however Im concerned about the adam walsh act.

Like 2257, from what I understand about the adam walsh act, also requires webmasters, primary and secondary, to hold records as well.

If this is the case, does the adam walsh act have to refer to the record keeping requirements outlined in 2257, which is of course still in the courts, in order for an inspection to take place?

What does the significance of the adam walsh act have on record keeping requirements?

A lot of it remains to be seen. The adam walsh act basically says that webmasters have to maintain docs cross reference all their urls with those docs and basically do almost everything that the primary producers do. There is more to it than that though. Also the proposed changes have just been published. the comment period ends soon then we wait to see how the final rules look when published and what comes of them in court.

Did you see what FSC Board Member Mark Kernes said in the GYF link in the initial posting?

I'm a member of FSC--are you? Hopefully, you have been and have renewed your membership, too.

Dave

Yes, I am a member, and have been for a little over 2 years now.

I guess i did not see the Mark Kernes posting.

Swampthing,

I am not an attorney and, therefore, unable to give legal advice.

Other FSC Board members are attorneys and are much more knowledgeable concerning the processes, nuances and strategies involved with the implementation of regulations by the DOJ and court challenges.

I have sent them an email and when I get a response, I'll be sure to post it for you. I wouldn't want to misstate the process or give you less than the best information from people qualified to do so. As you know it can get very complicated very quickly.

I hope you understand as I appreciate you passion regarding this matter.

Please bear with me.

Yours,
Redrob

Yes, that bothers me quite a bit too. They can't get one thing resolved and start working on something totally different.

Clarification from Reed Lee, FSC Boardmember:


I hope this helps.....

Thats pretty much what I assumed, but haven't seen much discussion on the issue.

I appreciate your responses. Thank you very much.

This is BIG-time, and IMHO Adult Webmasters and companies need to ramp up themselves to provide their comments to DOJ, lest DOJ tell a judge down-the-road that since very few Adult Internet folks commented (negatively), it must connote that it's not overburdening, and that the proposed new DOJ regulations are fine--YUK!!!

C'mon, folks, speak up now or be prepared for a lot potential 2257 crap in your future! jeezzzzz:-(((

Dave

Are there any direct links to information on how to comment, and possibly a list of comments already submitted?

YES---see the links in the initial posting comment of this link.

http://www.freespeechcoalition.com/F...view&coid=1073

Im wondering how many people are afraid to land themselves on the radar screen of the doj by making a comment?

Bump for the afternoon crowd of webmasters who are searching for a way to make their comments known to the DOJ.

More bumps to build awareness.

Make the message,
Don't delay,
'Cause your opinion counts.
Do it today!
-Burma Shave-

Mr Pinks, I have to disagree with this:

There can be no double standard for legal material. If material is legal, it is legal at all times. Nobody should be forced to pay to exercise their right of free speech. If someone wants to run a server and post porn for free, provided they have the rights to it, it is their decision.

Legal free speech is legal FREE speech - not credit card protected speech.

That's cool. I was just a thought. Too much free porn on the net. No big deal.