“We have been looking at this process strategically,” FSC Executive Director Diane Duke told XBIZ. “We want to hold the Justice Department's feet to the fire and bring to light a lot of the ways they are breaking their own policies and laws."
"We also want to have an economic foundation, showing that there is a burden, so for them to say that it's negligible is no longer valid.”
First, FSC commissioned a report from Washington-based Georgetown Economic Services, and hired a firm experienced in challenging legislative regulations to write a statement about the Justice Department’s disregard for established law and policy in the development of the proposed 2257 proposed regulations. This report can be found on FSC’s website.
Second, FSC submitted its own 32-page comment, drafted by attorneys Jeffrey Douglas and Reed Lee, pointing out flaws of the proposed regulations, including logistical impossibilities and constitutional violations, offering an alternative to the proposed record-keeping regulations.
Third, FSC launched a campaign to help adult businesses and professionals who wanted to participate in the public comment process. FSC compiled an industry statement that adult industry businesses and professionals could endorse in their own names or the names of their companies. For those who preferred to prepare their own comments, FSC provided support materials and offered to review and suggest revisions to statements.
"I believe we can put a huge hole in the way 2257 is implemented," Duke said.
If the 2257 rules and regulations are not changed substantially, FSC is prepared to file an injunction as soon as the revised regulations are released and again fight this battle in court.
For more information, visit the Free Speech Coalition website.