June 22, 2005 02:00am
2257 Announcement From Shane's World
Source: Shane's World
by: Company Press Release
Dear Affiliate Partner,
Shane's World Cash has been advised by our legal counsel to not provide the IDs of our models to our affiliates. Below you will find a letter from our attorney addressing our reasons. Shane's World has always followed government guidelines and rest assured we are 2257 compliant and take full responsibility for the accuracy of our documents.
If you have any questions or concerns, please do not hesitate to contact me at Webmaster@ShanesWorldCash.com
Shane's World Cash
The Law Office of Jeffrey J. Douglas
A Professional Corporation
1717 Fourth Street, Third Floor
Santa Monica, California 90401-3319
June 2, 2005
Re: Secondary Producer Records Pursuant to 18 U.S.C. ufffd 2257
To Whom it May Concern:
I represent Shane's World Cash. We received your inquiry concerning copies of records for secondary producers. I am very familiar with 18 U.S.C. ufffd 2257 in my capacities as a First Amendment and criminal defense practitioner, the Chairman Emeritus of the First Amendment Lawyers Association and the Chair of the Board of the industry's trade association, the Free Speech Coalition. I write this letter exclusively in my capacity as Shane's World Cash's attorney.
Despite General Gonzalez' efforts at reviving the concept of "secondary producers" in the most recent version of regulations in support of 18 U.S.C. ufffd 2257, the concept is not supported by the statute itself. The only case addressing the issue, Sundance Assocs. Inc. v. Reno, 139 F.3d 804, 807 (10th Cir.1998), held that the "secondary producer" requirements of the regulations to be unconstitutional. We rely on that holding, and further decline to violate the privacy of the performing artists by disseminating private data when not required to do so by law.
If you have any questions regarding this policy, please do not hesitate to call, or have your attorney do so.
The Law Office of
Jeffrey J. Douglas
by: Jeffrey J. Douglas