Law Firm Delivers 'Earth-Shattering' 2257 Letter to Feds

WASHINGTON — Experts on the Regulatory Flexibility Act asserted in a letter submitted during the recent 2257 public comment period that the Justice Department has failed to meet their requirement under the RFA to consider the impact of 2257 regulations on small businesses.

The letter, primarily authored by David E. Frulla, a partner in the firm Kelley, Drye, Collier & Shannon, honed in on the fact that the Justice Department apparently has done no research whatsoever on the economic impact of 2257 and the burden that compliance would impose on small businesses within the industry.

FSC Chairman Jeffrey Douglas told XBIZ that the RFA concerns cited by Frulla in his letter are “earth-shattering” for the Justice Department’s continuing efforts to enforce 2257.

“I don’t know how the Justice Department is going to proceed,” Douglas said. “If they ignore [the RFA claims] the statute will be enjoined — hopefully root and branch. If they comply, then they have to start all over again, and consider the economic impact of the entire statute.”

The Kelley, Drye, Collier & Shannon firm was retained by the Free Speech Coalition, along with Georgetown Economic Services (GES), to help communicate to the Justice Department concerns over the economic impact of 2257. GES conducted a study on the costs, and Kelley, Drye, Collier & Shannon was retained to present the legal arguments surrounding the RFA.

The firm previously has represented clients on RFA issues initiated by a wide range of federal rulemaking proceedings, including ones initiated by the Commerce Department, the Environmental Protection Agency, the U.S. Army Corps of Engineers, the Agriculture Department and the Federal Communications Commission.

“[T]here are thousands of small businesses in the adult entertainment industry that will experience a significant adverse economic impact if the proposed rule is implemented,” Frulla wrote. “Accordingly, pursuant to the RFA … the Justice Department is required to conduct detailed regulatory flexibility analyses … in connection with developing this rule.”

Frulla also observed that “while the adult entertainment industry’s overall economic contribution to the U.S. economy is large, the overwhelming majority of industry participants (and, likewise, of the FSC's members) are small businesses.”

Frulla argued that small businesses in the industry will “suffer substantial economic, administrative and other injury, which almost assuredly will force a significant number of them (particularly Internet-based businesses) out of business should the proposed rule proceed to final rule in its current form.”

Whatever the true economic impact of 2257 may be, Frulla asserted that the Justice Department simply has not met its responsibilities under the RFA with respect to researching that impact.

“In its proposed rule, the Justice Department states, in conclusory fashion, that it ‘drafted the rule to minimize its effect on small businesses while meeting its intended objectives,” Frulla wrote. “Yet nowhere in the proposed rule does the Department explain how it sought to minimize impacts on small businesses, nor is such consideration otherwise evident.”

This unsupported assertion on the part of the Justice Department “falls far short of what is required of agencies under the RFA, the SBA Guide and controlling case law,” Frulla wrote.

Douglas noted that the Justice Department not only failed to conduct any real analysis of the statute’s economic impact with respect to the newly proposed revisions to the regulations, the agency never considered the impact of the statute and regulations in their original form.

“They haven’t even gotten to step one of a long, complicated road,” Douglas said.

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

Rachael Cavalli, Manuel Ferrara Lead Latest From Jules Jordan

Rachael Cavalli stars with multi-XMAs winner Manuel Ferrara in the latest release from Jules Jordan.

Penny Barber Stars in Latest From Kink.com

2025 XMAs MILF Performer of the Year Penny Barber stars with Scarlette Moon in the latest installment of Kink.com's "Whipped Ass" series, titled "Deep Inside the Splash Zone."

Lauren Phillips Fronts Latest From MYLF

2024 XMAs MILF Performer of the Year Lauren Phillips stars with Nick Strokes in the latest release from MYLF, titled “Sweat, Cum, and Glory: Lauren’s Sexy Aerobics Routine.”

Nikita Bellucci Stars in Dorcel's 'M.I.L.F.S. Vol. 4'

Nikita Bellucci headlines the latest feature from Dorcel, titled “M.I.L.F.S. Vol. 4.”

Ashley Makes Her WIFEY Debut

Creator Ashley stars with her husband Kyle and Lil D in the latest release from Vixen Media Group studio imprint WIFEY.

Jennifer White, Vanna Bardot Headline Jonni Darkko's 3rd 'POV Anal Sluts'

Vanna Bardot and newly crowned XMAs Female Performer of the Year Jennifer White topline director Jonni Darkko’s third volume of “POV Anal Sluts,” from Evil Angel.

Leana Lovings Stars in Latest From Elegant Angel

Leana Lovings stars with Alex Legend in the debut episode of Elegant Angel’s new series “Demure Girls,” titled “Pillow Talk with Leana Lovings.”

'SheHerGirls' Launches Through Paysite.com

The braintrust behind PoleVixens has officially launched a new membership site, SheHerGirls, also through Paysite.com.

Angela White, Madison Ivy Lead New Threesome From Brazzers

Multi-XMAs winner Angela White and Madison Ivy star with Ricky Johnson in the latest release from Brazzers, titled "Couple or Throuple?”

FTC Invites Public Comment on 'Click to Cancel' Rulemaking

The Federal Trade Commission (FTC) announced this week that it is seeking public comment on whether it should amend its Negative Option Rule to better address deceptive or unfair practices.

Show More