Doing Response Comments to DOJ on 2257 - Need Info
 

I'm finalizing my response to the Justice Department and the Office of Management and Budget about the economic impact of Section 2257 regulations on small businesses - in its last draft, DOJ estimated only about 1,800 people in the US would need to comply with the regulations concerning simulations and lascivious images of genitals and pubic area. This is crazy-absurd-nutzo underestimation obviously and I wish to write a response that will shove it up their tailpipe. A search of Google shows over 24 million hits on a search for 2257 Compliance Statements. Those 1,800 folks must be really, really busy!

I need some verifiable facts. To start with, is there any way to determine the number of registered users at GFY?

Or using other online resources specific to this industry?

They guess that the time involved in complying with Section 2257 is six minutes per video, and that may be true in large production line houses, but I'm sure that's wrong by as much as a factor of ten to twenty to thirty for small business producers and secondaries. Any better information or estimates regarding the economic impact of Section 2257 compliance would be helpful, even the costs of using third party custodians.

Thanks in advance.

I encourage everyone to write. The comments are due tomorrow. More information is located at http://www.xxxlaw.com/articles/DOJ_R...the_Table.html

PS - thanks to Gram Ponante for his great article today - http://gramponante.com/xxxlaw-blind-...-naked-people/

Six minutes per video? That sounds low even for just scanning documents, filing them, and entering relevant information into a database and doing the hyperlinking to the docs, etc.

I used to be a computer programmer, so I created my own database in Access with multiple tables, and that took time. And then you have to do backups, etc., and that all takes time. And then you have to read the fucking idiotic regulations the government changes every few years. And then you have to talk to (and pay) your attorney so you can try and comply with the idiotic regulations the government has just published. And all that unproductive waste of time takes time.

Six minutes? Hahahahahahahah...

1. email the mods or owners of gfy. This is another site / forum that measures forums stats. I dont remember the name though.

I think a good place to start would be to tally the numbers of videos being released yearly from the largest sites. Ex rk releases 2 - 4 new vids a day. Brazzers 2 - 3 a day. Pimproll 2-3 a day. and many more putting out many videos everyday

Its a constant upkeep which overtime will on grow. This might be an aspect to include. For a small business owner or someone new to this it could be logistics nightmare dealing with 1000's of videos at a time. Take the number of videos or pictures multiplied by time it takes and it basically puts them out of business.

A real example is a site has 100,000 pages. Even at 6 minutes its a mess. 100,000 vids (6 minutes) = 600,000 minutes is 10,000 hours of work.

Bump for Joe, try theo at avn dot com:thumbsup

bump to the top.

Joe, ill give you a call in some 90min

I have a full time employee to deal with out 2 - 3 new exclusives and a few new dvd's a day. She works hard, she's a paralegal, and she could probably use help. 6 minutes is a joke, To cover your ass, the documents have to be studies to make sure they are filled out right and that nothing has been changed. Info has to be verified, ID's have to be confirmed as real, and confirmed as belonging to the model, expiry dates checked, copies made, scanned, filed, databased etc.

Doing it right takes a minimum of 10 times what they are suggesting.

Joe.. I'm not sure if you remember me but I believe we met a handful of times.

When I worked at Playboy, our local office in Sacramento had a full time dedicated person just to add to and maintain our 2257 records - and that was just at our office. That was just at our office - other offices had similar dedicated staff members, plus the legal department in Burbank had a small staff dedicated to just tracking 2257 information. On top of this, every time anything happened with 2257 in the news, in court, or if someone was inspected, it generated a round of conference calls with a dozen people....

Email me at [email protected] if you need more information.

One way to estimate the number would be to pick 200 random sites. See how many use Strongbox, or how many use NATS or whatever. If X% of your random sample uses Strongbox, probably roughly the same % of all adult sites use Strongbox.

Let's say you find that 4% of the adult sites (40% of pay sites) use Strongbox. We might then be willing to tell you that 50,000 sites use Strongbox. If 50,000 is 4%, there are about 1,250,000 adult sites.

Similarly you could count how many of your 200 random sites are in the Yahoo directory. If 1% are in the directory, and the directory has 10,000 sites in the adult categories, there must be about 1,000,000
sites.

Joe is doing the writing. Any volunteers to do the counting?

Here's how it should work...

ONE FBI agent stops by your location (not 4, not 8, not 16 like a fucking SWAT team).

The agent then asks you to produce the ID(s) for the young looking model or models they want to know about.

You provide them with the ID(s) necessary, and then they leave.

If you don't have the ID(s), or the model or models in question are underage, you get arrested.

Quick, easy, sensible.

This does not have to be a complicated, time consuming, fear-filled fiasco.

As long as you are not breaking the law you should not be treated like a criminal, or worse - like a terrorist!

Just streamline the process, and move on....

We are only a two person operation. So a very small business. I use 2257 snap and have my helper upload the docs. They do about 4 or 5 an hour. So half the day is taken complying.

This is for one pay site.

Edit: Just asked them they said they can do 2 or 3 an hour.

I dont like 2257 on many levels but the biggest is that the presumption of innocence is tossed out the window, Its logically incorrect to have to prove that a crime did not happen, is the next step to require anyone who sells alchohol to keep the IDs and info of every person who buys it from them?

The idea that I would have to prove that I did not commit a a crime that never happened is a very very slippery slope.

Joe,

I just emailed you with a user count for the gay webmaster forum we own in case it's not too late to work into your comment.

Incidentally, it has more than 1,800 members, mostly comprised of programs and affiliates. Where did they ever get that number from?