Attorney Walters Comments on Proposed 2257A

ORLANDO, Fla. — First Amendment lawyer Lawrence Walters, of the firm Weston, Garrou, Walters & Mooney, offered his opinion and commentary on newly proposed 2257A regulations, published by the Justice Department in the Federal Register today.

The regs are proposed as a counterpart to current U.S.C. 18 2257 regulations, which dictate federal labeling and record-keeping regulations for producers of sexually explicit content.

One of the key additions to current regulations being proposed in 2257A would implement provisions of the Adam Walsh Child Protection and Safety Act of 2006, which would require producers of depictions of simulated sexually explicit conduct to maintain records documenting that performers in those depictions are at least 18 years of age.

Currently, content containing scenes of simulated sexually explicit content is not regulated by 2257 requirements.

“Amazingly, the Department of Justice completely ignores the fact that the entire 2257 regulatory scheme was declared unconstitutional in the Connection Distributing case,” Walters told XBIZ.

“The DOJ turns a blind eye to this and claims that it will apply the 2257 compliance obligations on the producers of 2257A content, since the courts have repeatedly upheld their validity” he added. “This demonstrates the kind of denial that the government is willing to engage in to impose more burden on the industry.”

Walters pointed out that a “safe harbor” exemption had been included in the proposal. Producers of softcore or simulated content that was created for commercial consumption that certified regularly to the attorney general adequate record-keeping procedures had been put into place and that no models under the age of 18 were used in the content, could then notify the attorney general every two years to avoid unwanted prosecution.

“The substance of the regulations is not particularly surprising, although the ability to obtain a compliance exemption may be of useful to those producers that focus on 'softcore' product that does not include actual sexual activity,” Walters said.

The attorney also spoke other proposed 2257 regulations that, according to Walters, have not been clarified, inferring that additional proposals would increase the difficulty for producers to comply with the regulations.

“What is somewhat unclear is the status of the proposed 2007 regulations,” Walters said.

“Some of those have been modified by the 2008 regulations, but others remain untouched — such as the requirement that 2257 records include the original date of production of the material,” he described. “It appears that those proposals remain on the table — to the extent they were not amended by the proposed 2008 regulations, but this is becoming an increasingly complex and unwieldy administrative nightmare.”

As for the proposals published today, Walters added, “It is important to keep in mind that these regulations have not been adopted yet, but are merely in the public comment phase.”

Walters is a frequent lecturer on the subject of free speech, and has authored numerous articles for mainstream and adult publications [including XBIZ] and legal reviews. He has represented several adult industry members and businesses.

Related:  

Copyright © 2026 Adnet Media. All Rights Reserved. XBIZ is a trademark of Adnet Media.
Reproduction in whole or in part in any form or medium without express written permission is prohibited.

More News

Hailey Rose Talks New 'Titwoman' Showcase for Elegant Angel

Keisha Gray, Angela White, Octavia Red, and Blake Blossom. These are the well-endowed women who have played the character of "Titwoman" for Elegant Angel.

Digital Playground Premieres Ricky Greenwood's Feature Comedy 'In The Bag'

Digital Playground has dropped “In The Bag,” a ‘70s-inspired comedy from multi-XMAs winner Ricky Greenwood.

Jasmine Sherni Performs 1st Gangbang for Brazzers

Jasmine Sherni performs her first gangbang in the latest Brazzers release, "Operation Open Wide."

Carmen Valentina Stars in Latest Release From FreeUse

Carmen Valentina stars in the latest POV release from FreeUse.

Phoenix Marie, Cory Chase Star in Latest From MILFY

Phoenix Marie and Cory Chase star with Dan Damage in the latest release from Vixen Media Group studio imprint MILFY.

Paysite Confidential: Inside the Creator Economy's Shift Toward Ownership

For years, the adult industry’s creator economy has been defined by platforms — powerful engines of discovery, monetization and scale that reshaped how performers connect with their audiences.

Senator Urges DOJ to Crack Down on 'Obscenity,' Attacks OnlyFans

U.S. Senator Jim Banks of Indiana this week urged Acting Attorney General Todd Blanche to reestablish the Department of Justice’s defunct Obscenity Prosecution Task Force in a letter that targets OnlyFans while repeatedly conflating “obscenity” with legal adult content.

Reagan Foxx Headlines 'Mom's Little Cuck' From Reality Junkies

2023 XMAs MILF Performer of the Year Reagan Foxx toplines "Mom’s Little Cuck" from Mile High Media studio imprint Reality Junkies.

UN Experts Urge US, Canada to Prosecute Aylo, Others for 'Exploitation'

GENEVA – The United Nations Office of the High Commissioner for Human Rights (OHCHR) has issued a press release in which two U.N. special rapporteurs, cited as experts, accuse Aylo and other companies of complicity in sexual exploitation.

Clémence Audiard on Blending Gonzo With High-Style Eroticism

There's an unmistakable radiance that surrounds Clémence Audiard — a glow born of the power to manifest her own vision. With Clemence Crave, her self-funded and self-directed production house, Audiard has sculpted a universe entirely her own.

Show More