c-lo

A bit lengthy - suggestions are welcomed. Thanks.


"It is my opinion that the proposed 2257 record-keeping requirements are overly-burdensome and unnecessary and furthermore that they will result in few, if any, actual child porn producers & distributors being caught, processed, and rightfully imprisoned.

In an effort to save time and effort for every party involved, would it not be easier to allow secondary producers (many of which are merely individuals working from home) to list the address of the primary producer? This simple campaign adjustment would save time and money for the inspecting parties and secondary producers, as well as reduce tax payer money spent towards conducting these investigations.

The primary producer is the person who actually shoots the content and obtains the required records beforehand, so inspecting hundreds of thousands of duplicate records not only wastes the time of the inspecting party, costs extra tax payer money, and overly burdens the secondary producer, but, most importantly, it does nothing in the effort to thwart the actual creation and distribution of child pornography.

The adult industry does everything in its power to not involve minors in any stage of production and often takes the initiative to report those who are suspect in doing so. I feel, as do many in the industry, that the most productive way to stop the creation and distribution of child pornography is to work with the federal government, not against it. Creating these overly-burdensome record-keeping requirements gives the impression to not only me, but many, that we are considered guilty until proven innocent in the intentional misuse of minors.

Additionally, adult content producers have been keeping records for years in an effort to show that they in fact do not intentionally involve minors. Child porn producers have never kept records. Child porn producers will never keep records no matter what amendments you make to this law because they are doing something that is already illegal.

This law best (only) makes sense in serving as an additional violation that can be appended to those caught producing/distributing child pornography. However, I must stress that this is a large burden to apply to the legit adult industry in order to slap an additional charge onto the rapsheet of the actual producers of child pornography. In effect, you are creating unneeded and overly-burdensome rules for a legit industry (and inconveniencing yourselves) whilst actual child porn producers suffer not even the slightest inconvenience from these proposals.

In the last 3 years of being an adult webmaster I have seen few photos giving the impression of the individuals involved possibly being minors. In an effort to justify your campaign to thwart child pornography, I have attempted to locate such material via websites and search engines only to come up empty-handed. However, one quick search for “child porn” on torrent sites and peer-to-peer networks yields many results of actual child pornography. If this truly is a campaign to destroy child pornography and not simply appease those who oppose pornography by burdening the creators of legal adult content, why has nothing been done to stop the ACTUAL DISTRIBUTORS OF CHILD PORNOGRAPHY? The average internet surfer can find these files but the government of the most powerful nation in the world cannot?

I take a strong personal stance against child pornography, but I shouldn’t have to prove that I am not one of the producers of such content just because I have websites that link to content containing two consenting adults fornicating; which, if you allowed secondary producers to link to the primary producers’ location of records as I suggest, could easily be proven.

I would love to see actual child pornographers sent to prison; however, I believe you’re using all the wrong and least-productive methods to find them. Hopefully this will be realized before you cost American tax payers too much money, further suppress the rights of American webmasters, and cost yourselves too many resources in your vain and eventually-obvious counterproductive efforts."

Also, don't forget to SEND IN YOUR LETTER!

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baddog

You don't need the quotation marks. I have made some changes and hi-lited suggested mods

It is my opinion that the proposed 2257 record-keeping requirements are overly burdensome and unnecessary and furthermore that they will result in few, if any, actual child porn producers & distributors being caught, processed, and rightfully imprisoned.

In an effort to save time and effort for every party involved, would it not be easier to allow secondary producers (many of which are merely individuals working from home) to list the address of the primary producer? This simple campaign adjustment would save time and money for the inspecting parties and secondary producers, as well as reduce taxpayer money spent towards conducting these investigations.

The primary producer is the person who actually shoots the content and obtains the required records beforehand, so inspecting hundreds of thousands of duplicate records not only wastes the time of the inspecting party, costs extra tax payer money, and overly burdens the secondary producer, but, most importantly, it does nothing in the effort to thwart the actual creation and distribution of child pornography. (This sentence is a little long)

The adult industry does everything in its power to prevent (had split infinitive) minors in any stage of production and often takes the initiative to report those who are suspect in doing so. I feel, as do many in the industry, that the most productive way to stop the creation and distribution of child pornography is to work with the federal government, not against it. Creating these overly burdensome record-keeping requirements gives the impression to not only me, but also many, that we are considered guilty until proven innocent in the intentional misuse of minors.

Additionally, adult content producers have been keeping records for years in an effort to show that they in fact do not intentionally involve minors. Child porn producers have never kept records. Child porn producers will never keep records no matter what amendments you make to this law because they are doing something that is already illegal.

This law best (only) makes sense in serving as an additional violation that can be appended to those caught producing/distributing child pornography. However, I must stress that this is a large burden to apply to the legit adult industry in order to slap an additional charge onto the rap sheet of the actual producers of child pornography. In effect, you are creating unneeded and overly burdensome rules for a legit industry (and inconveniencing yourselves) whilst actual child porn producers suffer not even the slightest inconvenience from these proposals.

In the last 3 years of being an adult webmaster, I have seen few photos giving the impression of the individuals involved possibly being minors. In an effort to justify your campaign to thwart child pornography, I have attempted to locate such material via websites and search engines only to fail. However, one quick search for ?child porn? on torrent sites and peer-to-peer networks yields many results of actual child pornography. If this truly is a campaign to destroy child pornography and not simply appease those who oppose pornography by burdening the creators of legal adult content, why has nothing been done to stop the ACTUAL DISTRIBUTORS OF CHILD PORNOGRAPHY? The average internet surfer can find these files but the government of the most powerful nation in the world cannot?

I take a strong personal stance against child pornography, but I shouldn?t have to prove that I am not one of the producers of such content just because I have websites that link to content containing two consenting adults fornicating; which, if you allowed secondary producers to link to the primary producers? location of records as I suggest, could easily be proven. (Another very long sentence)

I would love to see actual child pornographers sent to prison; however, I believe you are using all the wrong and least-productive methods to find them. Hopefully this will be realized before you cost American tax payers too much money, further suppress the rights of American webmasters, and cost yourselves too many resources in your vain and eventually-obvious counterproductive efforts.

baddog

Another mod to the last sentence:

I would love to see actual child pornographers sent to prison; however, I believe you are using all the wrong and least-productive methods to find them. I hope that this will be realized before you cost American taxpayers too much money, further suppress the rights of American webmasters, and cost yourselves too many resources in your vain and eventually-obvious counterproductive efforts.

c-lo

Thanks for the pointers, baddog. I just did the quotation mark thing for GFY, not in the original letter. And I guess I forgot the word "prevent" existed in that one paragraph. Appreciate it.

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RawAlex

c-lo, in the end, your intial point about few CP producers getting stopped as a result if the main reason why the secondary producer clauses can (and likely will) be challenged in court. Similar to COPA and COPAII, the law doesn't further the stated intent of the law (stop child abuse), and further it does it in the most abusive and most labor intensive method possible.

All of the seconda

ry producer requiredments could be simply handled with a standardized document. Name of performers in the work, the month and year of birth of the performers (and date if it is the same month as thier 18th birthday), the date of the production, and a sworn statement by the primary producer that they have all the documents on hand at their primary producer, reference number XXXXXXX. it would accomplish the same thing without risking the privacy of information of the performers, and not requiring all sorts of people not involved in the contracting of performers to retain records on them.

The statement of the primary producer should be more than enough, because in reality they could provide false, misleading, or altered documents for an underage performer under the proposed rules and secondary producers would have no way to check it. Primary producers have the method to actually touch and see the ID material in question, which gives them an advantage.

There is no "honest" CP in the adult industry, there are occassional (maybe one or two cases a year) of underage performers attempting to get into a porn movie with false or stolen ID. I can think of two cases in the last couple of years, one female and one male performer that I can remember there being an industry wide notification.

CP isn't part of the adult industry. Burdening the adult business with a heavy paperwork load won't further the government's stated interest in the slightest. It does further the conservative agenda to limit the free speech rights of those in the adult industry, effectively raising the cost bar if free speech much higher, and forcing secondary providers to make their addresses public on their websites, which could lead to harrassment and thus cooling free speech.

Your comments are spot on!

c-lo

So should I leave it in? I agree they'll probably be challenged on that, so I hate to give warning (although I'm pretty sure they've already thought of it.)

I've noticed we're usually on the same page.

EDIT: Also changed rapsheet to rap sheet, so don't recommend correcting that anyone.

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