It is important to keep in mind that although 18 U.S.C. 2257 is the statute (law) that relates to recordkeeping for adult content sites, there are regulations that interpret and expand upon the statute. These regulations begin at 28 CFR 75.
One striking thing about the regulations is that it there were major revisions to it as of March 18, 2009; the application to content was made much broader after that date. Many of the changes were expressed on two levels: first, the type of content was expanded and second, the requirements were in many cases reduced based upon the level of that content.
In order to comply with these regulations, it is critical that a thorough analysis be done to determine whether the content is covered by the regulations, and if so, to what extent. This review should be conducted by counsel, if at all possible.
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