Hi, DeWayne,

If you followed the nuances of 2257 as closely as most of us in the industry do, you would realize that the situation isn't quite as cut-and-dried as you state.

First, there is no provision in the regulations to force an investigation as a result of a complaint, or even a group of complaints to the FBI about a given producer. If there were, disgruntled ex-models would be making accusations and the very limited resources of the Innocent Images division that handles such matters would be completely overwhelmed. The division, like all law enforcement offices, does its best to allocate resources where they will do the most good. Going after a dead producer is probably not high on their list, and unless Cobra starts shooting new content, doing an investigation will probably also not rank high on their list.

Second, there have been a grand total of maybe 20 inspections in total since the original 2257 regulations went into effect in 1995. The agent in charge of the team that handles 2257 inspections has indicated publicly that it is unlikely they will pursue prosecution of administrative violations (i.e., failure to update a 2257 address after a fire) provided that the records are available for inspection elsewhere.

I suspect that the 2257 address on the latest DVD release was simply ineptitude on someone's part when the graphics were being prepared; this was the first DVD after Bryan's death, so Bryan's sister or whomever had probably not dealt with the issue before and didn't know to (as we do) quadruple check all of the 2257 information before the disc goes to manufacturing. No one in their right mind would willfully put a police barracks as a 2257 address. I think that's pretty much a non-issue.

I understand that Bryan had converted his records to electronic format in 2005, so it seems likely he would have kept a disc with all the records offsite somewhere but of course, that's for someone else to figure out. I do agree that if the records were available, Robert would not be contacting models for copies of IDs, if in fact that's true.

So the truth is that any statement about Cobra's 2257 records being in violation (other than administrative violations, which are not of the highest priority) is nothing other than conjecture.

I have heard from credible sources I trust that several models had reported that Bryan did, in fact, do photo shoots when they were underage and then hold their content until after they turned 18. Even if this is the case, it will be nearly impossible to prove. There is no provision within 2257 to fix or verify the date a production is actually photographed, so if, as has been alleged, Bryan shot the scenes when the model was underage and had the model return after his 18th birthday to get the ID pics and the release signed, there would be very little evidence to prove when the content was actually photographed. And, since the guilty party is deceased, little good would come of it, other than getting the content removed from circulation.

I've heard enough from various sources, including models of ours that were solicited by Bryan, to be able to believe that a lot of unsavory things happened at Cobra Video. And I agree that if Cobra is selling DVDs or VOD for which no 2257 records exist, or the age of the models is questionable, that any such content should be pulled from distribution, in the same way that Pacific Sun pulled the four titles Sean was in. Cobra Video, and Bryan's estate, should not be permitted to profit or continue to profit from content that was illegally produced. And I hope that eventually the feds *do* inspect Cobra's records. But I just don't see that it is going to be high on their priority list when there is no evidence of ongoing criminal activity, the models in question were in their later teens, and the perpetrator of the crimes is deceased. It's frustrating, but that's the world we live in.

I can understand why people are passionate around this issue, but vengeance and revenge and so forth are generally not very healthy or positive actions to be taking on, particularly when the perpetrator is deceased. Sean is an incredibly intelligent and talented guy, and honestly, in my book, has a lot more to offer the world than being involved in porn. I think that he'd do really well to just move beyond the industry and put all of the nastiness behind him, and find a way to use his intellect and abilities in an industry where he doesn't have to deal with all the drama and backbiting.

I believe that the overwhelming majority of companies in our industry are run by honest people who do properly comply with all of the regulations required by our government. Companies who flagrantly violate the letter and spirit of the law, such as what Cobra is alleged to have done, *should* be taken to task and either brought into compliance or shut down.

I do hope the FBI investigates, but I don't believe in jumping to conclusions or making accusations when no proof is forthcoming.