CECash.com and my2257.com
 

For Immediate Release: June 27th, 2005

Trade News Corporation, N.V. the parent company of CECash and Edge Data Systems, NV have joined in a strategic development agreement to integrate their products into a new Webmaster Marketing and Compliance System.

CECash is a leading Internet company developing and marketing proprietary software and e-commerce technologies including credit card, traffic and password fraud control and tracking applications for its leading affiliate program and Web-based entertainment products which includes the famed Cybererotica.com.

Cybererotica is one of the oldest and most recognized adult entertainment websites on the Internet with over 2 billion unique visitors since 1996.

Edge Data Systems CEO David Slaughter made the announcement that my2257? and CECash have joined forces to create a site marketing tool based on Trade News Corporation patent pending technologies and intellectual properties with my2257? as the compliancy module for 18USC2257 requirements.

Spokespeople for the two entities stated that they believe this strategic development alliance will fill a great need for 18USC2257 adult affiliate marketing tool. ?We believe the ability to generate compliant site marketing materials will be the key to an affiliate program' s continued success and CECash has always been a leader in developing cutting edge products?, said Guy Mizrachi of CECash. My2257? offers CECash the ability to combine their technology with a truly database ready compliance tool. We expect more details on this exciting product to be announced shortly, said David Slaughter.

CECash.com and my2257.com will co-market this exciting new product under a co-branded product name.

edit - nevermind.

See he retracted his statement

Congrats on the deal guys.

Yes, I did, because I am too busy to sit here on GFY all night explaining why your system is not compliant (as previously advertised) and frowned upon my leading industry attorneys.

Perhaps this might help clarify what Newbreed is referring to...

Sec. 75.2 Maintenance of records.
...
(e) Records required to be maintained under this part shall be
segregated from all other records, shall not contain any other records,
and shall not be contained within any other records.

(f) Records required to be maintained under this part may be kept
either in hard copy or in digital form, provided that they include
scanned copies of forms of identification and that there is a custodian
of the records who can authenticate each digital record.

Yes - We do that
What is the Question?

We have the 2257 Data Management System that does ONLY 2257 records and then the OPTIONAL producer module that segregates the other info from the database.

We have been reviewed by multiple Attorneys so far and have closed a number of large accounts after legal review.

To amplify it just a bit further... From the 2257 Client Handbook authored by two leading attorneys, Paul J. Cambria and Roger W. Wilcox...

from page 30 of the above mentioned document...

2.2.5.1 What Cannot Be Kept In 2257 Records?

Producers should first note that 28 C.F.R. 75.2(e) warns that ?[r]ecords required to be maintained under this part shall be segregated from all other records, shall not contain any other records, and shall not be contained within any other records.?

The rules obviously anticipate a discrete, contiguous record keeping program that will not require authorized law enforcement agents to hunt through a convoluted filing system. Violation of the records segregation requirement exposes producers to criminal sanctions.

Consequently, it is important to ensure that extraneous documents such as model releases, medical records, and personal information not required by 2257 be excluded from 2257 records.

Indeed, given that many states have laws protecting confidential information such as HIV status, there are reasons beyond the 2257 rules that augur in favor of carefully vetting the materials placed in 2257 records.

... and from page 32-33 of the same document...

An analogous system can be created and maintained in a digital environment, and probably more easily. However, if you do choose the digital process, keep the records on a stand-alone PC that is not connected to your network, and which does not contain any information other than that required for 2257 compliance.

This will meet the segregation requirement of 28 C.F.R. 75.2(e), and will also ensure that inspection of your records and/or seizure of your 2257 records does not interfere with your business operations.

"Consequently, it is important to ensure that extraneous documents such as model releases, medical records, and personal information not required by 2257 be excluded from 2257 records.

Indeed, given that many states have laws protecting confidential information such as HIV status, there are reasons beyond the 2257 rules that augur in favor of carefully vetting the materials placed in 2257 records."

These are ONLY in the producers module and do not pertain to the 2257 record keeping parts of the program. Your looking at two seperate modules.
DON'T buy the additional producers module if you don't have a need for it.
It's that simple

That's the easy part, could have been done in a few hours if you were on it hard. But what about the second, and certainly more important text...

"An analogous system can be created and maintained in a digital environment, and probably more easily. However, if you do choose the digital process, keep the records on a stand-alone PC that is not connected to your network, and which does not contain any information other than that required for 2257 compliance.

This will meet the segregation requirement of 28 C.F.R. 75.2(e), and will also ensure that inspection of your records and/or seizure of your 2257 records does not interfere with your business operations."

So let me get this straight...

If I run your software without the optional Producers' module, I'm compliant... but if I DO decide to run the Producer's module, I violate the regs and then I become subject to penalties.... Interesting... are you going to take it up the ass for me from Bubba, my cellmate?

I have something for both of you to think about in regards to your solutions.

Inspector stops by and says, I want to see docs for these people... You say sure! The machine is right over here, I'll pull them for you right now. He says, No need! I'll just take the machine with me and have my team go through it with a fine tooth comb for the next 3 months. (or until we find something)

I say print every friggn thing out and file it.

Well, if you are keeping these kinds of records without a backup system in place then you're in the wrong line of work... What I would suggest would be a system with removable hard disks in drawers so you can plug your backup drive in, make any of your changes to your 2257 records, and then use SyncBackSE from www.2brightsparks.com to automatically do the backup to the spare disk.. then when it's done, undock it from the machine and then the inspector can take whatever they want... All you have to do is plug your backup into another machine and keep on going...

damn lol

Ben - on this I absolutely agree with you.

BACK UPS are a must. Export to paper, CD, DVD, Tape any thing or way you want and keep it where you know it is safe. SyncBackSE is a GREAT way to sync or restore.
Just be as covered as you can be!

We have redundant servers running at our facility and collocation that back up nightly. We also have hard copies store off site.

NEVER TO SAFE

Will Slaughter Productions be giving out docs for all past content purchases that it has had? I need to talk to someone asap to start making arrangemts to get these docs.. I don't like going to a site that just says closed down.. lol..

I hope Dave is willing to take care of past content sales before trying to push other creations and forgetting about those who purchased from him in the past..

Maybe someone can ICQ me.. 847-00-583

Media
Epic Cash

[QUOTE=2257-Ben]Well, if you are keeping these kinds of records without a backup system in place then you're in the wrong line of work... QUOTE]

Yeah man, you know who your talkn to huh :1orglaugh

Thats not the point - You think I would be bumed out because of the machine??? (wow)

We would rather not have them take HDs, machine, what ever with them to go through at their leisure. They can sift through filing cabinates for what they need. We do have everything digitally as well in a custom database solution we built last year... All 17 years worth of docs. But thats hidden somewhere within close reach. We will be pointing them to the 3 big ol filing cabinates with security cams over each one if need be. :pimp

An inspector CANNOT just confiscate the computer without any proof of non-compliance. He has to inspect BEFORE he can determine whether or not the computer in question becomes 'evidence'. That being said, we do have a stand-alone application they could use to get informtation out of your database that is read-only, which satisfies all known facets of the published regs.

:1orglaugh

Just let us know what you need.
I'll ICQ you with the contact info for this

[QUOTE=SiMpLe]
... and have it lit with a 25 watt light bulb for them to read all of those paper records... :321GFY

Great, will be looking for the authorization request...

[QUOTE=2257-Ben]Can you use Black Light????

or run it on multiple machines

Sent request - says your offline

Hrmm.. that's odd.. I'm right here online... Post an icq here or try to resend.. My status is set as available

rtesent
Hit me at 1586709 and lets see if it goes that way
or call me toll free at (877) 9my-2257

[QUOTE=2257-Ben]In the hottest part of our warehouse :thumbsup

Im not flaming you guys or your solutions, I have sent many affiliates to newbreeds solution already. But I always tell them to print it all out and only use the digital db for themselves.

I'm also trying to get the point across here to the readers of the thread.

Sure, as long as you use flourescent dye ink... The law says they have to be legiible, but it doesn't say whether they have to be read in normal ambient light... (I just love the law... it's so twisted...)

[QUOTE=SiMpLe] I didn't think you were! Just airing out the issues, which is a good thing for everyone.

and Newbreed's software can do that exteremely easily and well.

SiMpLe:

I agree with you!
You can NEVER have too many copies.

Since 2001 we have done our model release in 3 part carbonless so the original goes to custodian of record location, yellow copy stays at the studio and pink copy is stored off site.

We keep a set of ID's with each copy and a copy of their work agreements, HIV test and model interview with each copy of the release. We did this in the event of a catastrophic incident such as fire at the studio or our custodian of records address.

Backups are your lively hood in this industry

So our new release needs to be in flourescent dye ink and stored under black light. Can we say that it is for Archival purposes?

Yeah. to prevent bleaching of the records and aging of the paper due to ultraviolet exposure from sunlight.. this is due to the arduously long period for which the records must be archived...

LOVE IT!
Think the DOJ will buy it?
LOL

I do, you think it's a joke?

do we put a black light bulb in the scanner?

In addition.......

my2257/David Slaughter...... this is GFY, the biggest industry board on the net. I would suggest you take the page views, questions, traffic, and inquiries very seriously if you want to continue selling your $3,000.00 solution to people here.

Maybe. Do what you think you can to continue to sell a non-compliant solution.

Tell you what Dave, we are going to stop trying to help you out in terms of giving you a clue as to how to become compliant with your software. Your clients will find out soon enough where your solution is not only short of the law, but also how it cannot help them cater to their affiliates or preserve the downward flow of information that can bring them newer and possibly more conductive revenue streams.

Good luck. :)

Im interested in learning more about it if it can help make things easier

Sorry, had to eat dinner, I was famished!

Well, I would have to guess that it depends upon how good your attorney is and whether he can mount a defense based upon the fact that the records printed in flourescent ink are entirely legible... It's not like they specified the format for the hard copy document (which is sort of a blessing...) and the law simply says the records must be legible.

LOL, you certainly wouldn't get that impression by reading the comments for the 2257 regulations, particularly in light of the record keeping requirements for streaming video, etc.