Redrob

Released 7/27/07

FSC Launches 2257 Public Comment Campaign

Canoga Park, CA ? Today, the Free Speech Coalition released its ?2257 Guide for Public Comment? and launched a campaign to garner industry participation during the DOJ?s public comment period for the 2257 proposed rules and regulations.

The guide educates members of the adult entertainment industry about how and what to communicate during the public comment period. Input about the new rules and regulations released July 12, 2007, will be accepted by the Department of Justice through September 10, 2007.

?Government regulations must not pose an undue burden on the industry they regulate,? said Diane Duke, Free Speech Coalition Executive Director. ?The Department of Justice has taken the position that the burden 2257 imposes on the industry is ?negligible?. It is up to us to prove otherwise.?

The current regulations are just proposals; therefore, they have no force of law at this time. They merely represent the current thinking of this administration. After the public comment period, the Department of Justice reviews comments and then issues final regulations with an effective date. The process typically takes many months.

Unless the proposed regulations are radically changed in ways more favorable to the adult entertainment industry, it is the intention of FSC to seek a court order preventing implementation of the proposed ?final? regulations after they are announced, but prior to the effective date.

?Full industry participation in the public comment period is critical,? Duke said. ?Failure to speak up now is tantamount to agreeing with the DOJ?s assessment of 2257?s burden on the industry. If the Department of Justice disregards our input, at the very least, we will have built a solid foundation for our next phase of litigation.?

In addition to the 2257 Guide for Public Comment, FSC released a Frequently-Asked-Questions (FAQ) document to help answer industry questions raised by the release of the proposed rules and regulations. Both documents will be posted on FSC?s website at www.freespeechcoalition.com by Monday July 30th. They will also be included in next week?s X-Press e-newsletter as a service to FSC members.

Contact: Diane Duke [email protected] 818-348-9373

Link to proposed 2257 Regulations:

http://www.freespeechcoalition.com/w.../2257_Regs.pdf

RawAlex

Woohoo! Only, what, 45 days after the press release. Anything else since?

Redrob

Do you have to be asked more than once?

MrPinks

LOL, yeah seriously since the deadline is what TOMORROW??

RawAlex

Redrob, if FSC is serious about this, it should have been an ongoing thing. A press release EVERY WEEK during the period with updates. Include the comments in the press releases from key people. Get on the boards. Post regularly. Answer questions, make points, suggest talking points, provide insight and information to people to properly write such a commentary.

Coming to the board a couple of days before due date and talking down to people who might not have commented isn't exactly going to make it happen.

Considering that 2257 is one of FSC's core issues for the last couple of years, I would think that you people would be all over the boards and all over the adult media pushing the issue literally on a daily basis.

Today is a pretty late time to get started.

Redrob

I have personally made over 30 posts on this issue with many bumping Dave's posts which said it all so eloquently.

Have you sent in your comments?

RawAlex

I am not a US citizen, and my comments would not be accepted.

Redrob

If you are not a citizen and not affected by 2257, why are you trying to influence the discourse between those that are affected?

Just interested...

Redrob

From the FSC website link:

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

Guide to Submission of Comments for 2257 New Rules and Regulations
July 12 - September 10, 2007
By:
Posted: 7/30/2007


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.

crockett

I'll have to agree with this.. Where has the FSC been the last month? They sure as hell haven't been making the issue at hand widely known on the various forums, where most of us meet and hang out or at least read.

__________________
In November, you can vote for America's next president or its first dictator.

Redrob

See above.

RawAlex

Because 2257 affects ALL porn producers, affiliates, porn sites owners, and everyone down the chain right to the guys who print the magazines. The rules that exist in the US affect my business because it will change how US based companies will potentially operate.

Anything that restricts business is everyone's concern, no?

RawAlex

most of your posts on the issue have been variations on:

outside of this single thread, exactly how many threads have been started here by FSC board members on this subject?

Exactly how many press releases have been issues since August 1st?

Exactly how many comments by known individuals or companies have been forwarded by FSC to the adult press for publication?

Exactly how many article have been written in X-biz and AV-N as a result of FSC action, press releases, or information updates on this subject?

No beating around the bush, please.

Redrob

Here is a thread started by me a month ago dealing with comments on 2257:

https://gfy.com/fucking-around-and-business-discussion/759629-guide-submission-comments-2257-rules-regulations.html

Other than that, mostly comments and bumps on other peoples' threads.

Here is a press release from FSC on 9/6/2007:

http://www.freespeechcoalition.com/F....asp?coid=1082

Remember that we are talking about a period of less than two months.

RawAlex

Okay Rob, I apologize. It is clear to me that the FSC has been full court press on this issue.

Pleasurepays

that is what you have done? i thought the very purpose of the FSC was to fight things like this? your publicity campaign to rally people and create awareness is a thread on GFY and a press release?

did the new "we're going to fight piracy now" financial drive get you sidetracked?

Redrob

There has been no "fight piracy now" financial drive that I know of???

Did someone ask you to donate to fight piracy? Who? When?

FreeHugeMovies

I tried to pay my membership fees, but I couldn't pay online. I then e mailed someone there, and the e mail was never returned.

FreeHugeMovies

The person I e mailed was [email protected]

Redrob

I forwarded your concern on to Diane, the FSC ED.

davecummings

The lack of action by many GFYers who have seen this stuff repeated/bumped/etc for the last month is UNBELIEVEABLE; yet, now, some of them are bitching about tomorrow being the deadlne.

:-((((((((((((((((((((((((((((((((((

dave

__________________
Dave Cummings
www.davecummings.com
www.davecummings.tv
San Diego

Email--- [email protected]