secondary producers have always been required to maintain model IDs
 

according to the new regulations, secondary producers have ALWAYS been required to maintain model indentification.

" Finally, regarding personal
information about performers that must be transmitted to secondary
producers, the Department again notes, first, that such information is
already required by the current Part 75 regulations, and, second, that
none of the commenters presented any evidence that a hypothetically
possible crime, such as the stalking of a performer, was in any way
tied to the dissemination of the information about a performer provided
to a producer in compliance with Part 75."

so i've been reading many posts from gallery submitters, thumb-preview TGP owners and other affiliates that they are taking down all their hardcore images and going all text or softcore before june 23rd.

but according to the regs, if they didn't have the model IDs up to this point, they've been out of compliance. (at least according to that part I just copied here).

so, if the DOJ launches a major initiative, can affiliates be punished for posting all of that 'promo' material up to the point they took it down this month? does taking it all down today really exempt you from inspections and possible punishment?

if this is true, sponsors are effectively hanging their affiliates out to dry by not providing documentation

They broadened the definition of secondary producer. Schwing.

i see. so under the first version of this law, there was no standard definition of 'secondary producer'?

under this version, a secondary producer is:

(2) A secondary producer is any person who produces, assembles,
manufactures, publishes, duplicates, reproduces, or reissues a book,
magazine, periodical, film, videotape, digitally- or computer-
manipulated image, picture, or other matter intended for commercial
distribution that contains a visual depiction of an actual human being
engaged in actual sexually explicit conduct, or who inserts on a
computer site or service a digital image of, or otherwise manages the
sexually explicit content of a computer site or service that contains a
visual depiction of an actual human being engaged in actual sexually
explicit conduct, including any person who enters into a contract,
agreement, or conspiracy to do any of the foregoing.



that covers TGPs and gallery submitters. but earlier they say that a movie theater wouldn't be forced to comply. how is a movie theater NOT a secondary producer under these definitions?