AP,

My understanding of the CURRENT regulation is that it only requires that the performer's "name, date of birth and such other indicia of his or her identity is required". No mention of identifying numbers, address or phones numbers are mentioned.

The PROPOSED regulation does state that "sufficient specific information" be provided so that the issuing authority can access the information. That MAY require that the numbers and/or address of the performer be provided, but that is something for the attorneys to sort through.

Regarding who has to maintain the records.....CURRENT regulations state: Title 18 USCS 2257 (a) "WHOEVER PRODUCES ANY BOOK, MAGAZINE, PERIODICAL, FILM, VIDEOTAPE, OR OTHER MATTER WHICH.......", must maintain the records. Producer means "any person, including any individual, corporation, or other organization who produces, manufactures, or publishes any book, magazine, periodical, film, video tape or other similar matter and includes the duplication, reproduction or reissuing of any such matter, but DOES NOT include mere distribution or any other activity which does not involve hiring, contracting or managing, of otherwise arranging for the paticipatinon of the performes depicted". No mention in the current regulation is made of a secondary producer.

In the PROPOSED regulation, yes, a secondary producer is added and he/she is required to maintain the same records as the primary producer.

Another interesting point that I haven't seem mentioned on the board is the fact the Free Speech Coalition (FSC) announced last week that they have prepared a challenge to the proposed regulations in case the Department of Justice places them into effect in essentially the form as the initial proposal was written. Hopefully, the implementation of the proposed regulation will be stayed while it works its way through the court system.

Bill