CONTENTS:
I Industry Statistics -- The United States
II Industry Statistics -- Benefits to California
III Definitions: Adult Entertainment, Pornography, Obscenity
IV A Basic Right: The Private Enjoyment of Adult Entertainment
V The Mainstreaming of Adult Entertainment
VI The Adult Entertainment Industry and HIV
VII Free Speech Coalition and Public Policy
I. INDUSTRY STATISTICS - THE UNITED STATES
Overall
In February of 1997, US News & World Report stated that adult entertainment
was estimated to be an $8 billion economic giant. The industry trade
publication, Adult Video News (AVN), estimated that the true figure, even
then, was $2-$3 billion higher than that. A 2002 AVN survey reported $4
billion in retail sales on the West Coast of the United States, a region
that generally accounts for a third of such sales. Various gross income
totals for the industry have been estimated by a variety of mainstream news
sources, but exact, reliable figures are simply not available.
What is certain is this: adult entertainment is a significant economic
engine. The following compilations of the best available data leave little
doubt of the contribution of the industry to the economic prosperity of the
nation. The State of California -- since major segments of the adult
industry are located there -- is especially benefited economically.
NOTES ON SOURCES FOR STATISTICS
The information used in the following statistical reports was derived from
numerous sources, including: a survey of 5000 retailers who answered an
annual national questionnaire composed and analyzed by Adult Video News (AVN),
the trade publication of the adult video industry (See AVN, January 2003);
Paul Kagan & Associates and the Video Software Dealers Association (VSDA),
the trade association for the entire home video industry, provided certain
relevant information. Additional data came from a special survey of mail
order and Internet content providers and from AVN Online. Information in the
exotic dance sections of this report is based on statistics collected from
targeted cities and specific clubs. Performers have also provided input.
Other information was drawn from a 2004 report by Citizens for
Responsibility and Ethics in Washington (The CREW report, in turn, drew
heavily from Obscene Profits: The Entrepreneurs of Pornography in the Cyber
Age by Frederick S. Lane). Other sources include Yahoo! Internet Life, "Sex
and the Internet - A Special Report,” May 2001; A National Research Council
Report; an MSNBC survey; a Forrester research report; a 2002 US National
Academies' report on Youth, Pornography & the Internet; a U.S. News and
World Report story; a 2003 study by Palisade Systems; and a report by
Websense, Inc., a provider of employee filtering software.
DVD And Video
The Video Software Dealers Association (VSDA) estimates that of the 60,000
retail outlets in the United States that stock home video, 25,000 outlets
carry adult titles. These retailers include such major chains as Virgin
Megastores, The Wherehouse, Tower Video, Palmer Video, Movies Unlimited,
West Coast Video, Movie Gallery and many others. In addition, hundreds of
small boutiques, large mail order companies and Internet websites sell adult
DVDs and tapes directly to consumers.
In the United States in 2002, adult video and DVD rentals and sales
accounted for 29.1% of the gross income in stores that carry both mainstream
and adult products, for a volume of over $3.95 billion. This figure includes
transactions in retail outlets but does not include sales through mail order
or over the Internet.
Hotel Adult Movie Rentals
An estimated 40 percent of the nation’s hotels offer adult movie options,
according to a 2004 report by Citizens for Responsibility and Ethics in
Washington (CREW). Adult movies account for about 90 percent of pay-per-view
revenue, says the CREW report. Based on estimates provided by the hotel
industry, at least half of all guests at hotels such as Marriott and Holiday
Inn pay to view adult movies. These orders result in approximately $190
million a year in sales.
Fantasy Phone Sex
Fantasy phone sex generates between $750 million and $1 billion in revenues
each year with as much as 50 percent being retained by U.S. long distance
carriers (from the CREW report).
Satellite And Cable
Satellite and cable operators, according to Kagan Research, earn just under
$800 million a year from adult movie subscriptions and pay-per-view orders,
roughly 40% of pay-TV on-demand revenue. All of the leading cable and
satellite TV providers - including Dish Network, DirecTV, Comcast and
Adelphia offer adult content (Adelphia offers soft-core programming only).
The Internet
An estimated 34 million people visited adult entertainment sites in August
2003, about one in four Internet users in the U.S. (Nielsen/NetRatings,
August 2003).
One percent of American websites are adult in nature (SurfWatch.com, June
2000). However, these sites account for almost 40% of all Internet traffic (SexTracker.com,
May 2001) and are by far the most visited sites on the Internet.
The 2002 US National Academies' report on Youth, Pornography & the Internet
noted that the number of paying subscribers to adult Websites is on the
order of several million in the United States, and may be as high as 10
million. On average, each paid subscription generates $20 to $40 per month
in revenue.
Traffic volume is staggering. SexTracker, a Web service that keeps an eye on
some 26,000 adult sites, reports that on an average day as many as 60
million unique visitors land upon those sites. Taken together, the top five
sex sites receive just under 4 million unique visitors every day. To put
that in perspective: The world's top five news sites in 2001, including such
heavyweights as MSNBC.com and CNN.com, received a total of only about 2.5
million unique visitors per day. (Yahoo! Internet Life, "Sex and the
Internet - A Special Report", May 2001.)
A 2001 Forrester Research report claimed 19% of North American users were
regular visitors to adult content sites. Of that 19% approximately one in
four were women, 46% were married and 33% had children.
Websense, Inc. a provider of employee filtering software, says that the
number of adult entertainment Websites in their URL database is more than 17
times greater than it was just four years ago, surging from approximately
88,000 in 2000 to nearly 1.6 million sites in 2004.
V. INDUSTRY STATISTICS – CALIFORNIA
Benefits to California – The Exotic Dance Industry
In California’s exotic dance industry, there are an estimated 7500 full-time
dancers with another 5000 working part-time. These entertainers represent a
broad range of women, including students, professional women and single
mothers as well as exotic dance professionals. What they all have in common
is that they enjoy the financial independence of self-employment in the
adult entertainment industry, and many find exotic dance to be the perfect
outlet for their erotic artistic expression.
There are over 175 exotic dance clubs in California. The clubs create over
20,000 jobs in the state, while generating almost $1 billion in revenue. The
dance industry brings in an estimated $500,000 to local governments in tax
revenue.
In the exotic dance industry, many entertainers earn 5-6 times the state's
official minimum wage or even more as headliners. Generally, dancers choose
their own working environment and work schedules and enjoy a level of
financial independence not found by women in other areas, in some cases
opening a business with their earnings. In addition, female dancers earn 3-4
times the amount of money earned by their male counterparts and considerably
more than in most traditional female jobs. The adult entertainment industry
is one of few industries where this is true.
Benefits to California – Video and DVD Rentals and Sale
In 2003, approximately 2800 retail stores carried adult videos and DVDs for
sale and/or rental in the State of California. The average store stocked
over 850 different adult tapes and DVDs for rental or sale, with an average
of 75 different new titles added weekly. Most stores had a near-complete
turnover in adult stock every 12 weeks.
During 2002 in the United States, stores reported a total of 801 million
rentals of adult tapes and DVDs, almost all of which were produced in
California. Nearly 130 million of those rentals took place here in the
state. If each of those rentals were for one day only, at a typical $3
rental fee, a minimum of $31 million in sales taxes would have been
generated for the State of California. Of course, the actual sales tax
revenues to the state are much larger, since the average rental is longer
than one day and for more than $3 per day.
The wholesale sales value of tapes and DVDs sold to retailers from producers
and distributors in the United States in 2002 totaled $919 million, with
nearly $130 million in wholesale sales to retailers in California.
Adult products are often the primary profit center for non-chain video
stores. Adult videos carry higher rental fees, rent for longer periods, and
are more likely to convert to sales. Without adult product, many of
California's retailers that carry adult videos would be forced out of
business, costing the state thousands of jobs.
Benefits to California - Manufacturing
The adult video business is made up of producers, manufacturers (who
duplicate and distribute their own as well as other producers' product),
wholesale distributors, retailers (including Internet sites) and mail order
companies. In California alone, Adult Video News has identified 175
manufacturers, providing employment for almost 5000 California residents. An
additional 60 wholesale distributors and mail order outfits in California
employ upwards of 1000 more workers.
These figures do not include the numerous producers and publishers of adult
magazines and novelties, which are economically significant industries in
their own right.
Several hundred performers employed in the adult movie industry reside in
California, as do thousands of technicians, directors, editors, producers,
makeup artists, art directors, designers, photographers, line producers,
lighting technicians, cinematographers, artists, computer experts, camera
operators, caterers, drivers, janitors, builders, Foley artists, musicians,
etc. Each of these employees pays state income taxes.
Many of the technicians and artists who work in the "mainstream"
entertainment industry have previously worked behind the scenes in the adult
movie business, demonstrating that the adult industry provides a training
ground for people wanting to work in Hollywood. Many continue to work both
in mainstream and adult productions.
Benefits to California – Mail Order
Mail order provides a means for distribution of adult products with minimal
intrusion into the community, and substantial privacy for the consumer. A
survey of mail order providers conducted by the Free Speech Coalition in
1998 established that in that year, there was $200 million in adult video
sales, plus additional millions in sales of magazines, lingerie and
novelties. The sales of these products generate tax revenue and employment
in California, where most of the product manufacturers are located.
Mail order and related shipping in California generates so much revenue that
following the 1999 United Parcel Service strike, the U.S. Postal Service
assigned a special sales staff to encourage the adult industry to keep using
the U.S.P.S.
Benefits to California – The Internet
California has the highest relative percentage of Adult Internet users of
any state in the union. In 2000, 13.62 million Californian adults used the
Internet, 15.3% of the total United States adult Internet population. (ACNielsen's
Homescan Net*Views Survey, May 2000)
Even more important, in terms of benefits to the state, California leads the
country in hosting adult websites. These are sources of high-paying,
technically sophisticated jobs. Entrepreneurs are attracted to these
businesses because of the low capital investment required for start-up. The
adult website industry helps keep creative, talented people in California,
and attracts additional technicians and entrepreneurs from around the world.
Each website also provides employment for models, dancers, photographers,
graphic artists and many others.
III. DEFINITIONS: ADULT ENTERTAINMENT, PORNOGRAPHY, OBSCENITY
In this paper we have used the term “adult entertainment” rather than
“pornography,” although, of course, many forms of adult entertainment are
referred to as pornography in the common usage. However, the word is
frequently misused by those who try to equate “pornography,” a word with no
legal meaning, with “obscenity,” a term which has a legal meaning with
specific attributes detailed by the United States Supreme Court in Miller v.
California (1973).
Obscenity is material deemed by a jury to be outside of the protection of
the First Amendment, criminalized by California and most other states as
well as in federal law. Pornography, on the other hand, unless it is
determined to be obscene in the courts, is fully protected by the First
Amendment. In fact, Webster's dictionary defines pornography as "writings,
pictures, etc. intended primarily to arouse sexual desire." By this
definition, much of society's poetry, music and other art forms could be
described as "pornographic." Henry Miller's Tropic of Cancer, James Joyce's
Ulysses and the film Carnal Knowledge and dozens of other literary works,
museum exhibits and artworks, as well as adult entertainment products have
been accused of being “obscene.” Almost all of them have been vindicated in
court and restored to the marketplace.
While community standards play a significant role in determining what is
legally obscene, the fact is that because one community is offended by a
book, film, or website does not render the communication illegal. Only a
small percentage of commercial adult entertainment has ever been charged as
being obscene; and of those, few have been convicted. Moreover, titles
condemned as obscene in one jurisdiction might be deemed to be perfectly
acceptable in most other parts of the country.
Another problem with the word “pornography” is that our society is greatly
(and rightly) concerned with the problem of materials involving sexual abuse
of children, often called “child pornography.” Those who wish to portray
adult entertainment as evil or illegal intentionally confuse the words
“child pornography” and “pornography” as they try to influence legislation
or public policy, thus making it appear that the two are one and the same.
Nothing could be further from the truth. Adult videotapes sold in general
release and adult video stores include only consenting adults. Careful
records are kept documenting the ages of all participants. Likewise, in the
exotic dance portion of the industry, all dancers are required to be of
legal age and are recognized as consenting adults based on documents that
must be presented to the club by the dancers themselves.
The word “pornography” is also frequently misused by those who seek to
portray adult entertainment as violent, involving exploitation, rape and
coercion of various kinds. While it is true that a small sub-genre of adult
product includes thematic portrayals of non-consensual sexuality, materials
made and distributed by the professional adult entertainment industry in the
United States do not contain any actual rape, coerced sex, sex with animals,
violence, incest or child pornography. Furthermore, easily 90% of the
material produced and distributed over the past 15 years portrays fully
consensual acts (oral sex, anal sex, group sex, etc.). Most of the remaining
10% is classified as specialty material (i.e., foot fetish, tickling fetish,
bondage, spanking, etc.) which generally does not contain explicit sex, but
which still involves, and is consumed exclusively by, consenting adults.
IV. A BASIC RIGHT: THE PRIVATE ENJOYMENT OF ADULT ENTERTAINMENT
Looking back as far as the first publication of Playboy in the Fifties and
topless craze in San Francisco in the early Sixties, one can see a natural
evolution in which the adult entertainment industry has both benefited, and
benefited from, the general liberalizing of attitudes about sexuality in
this country.
Over the last twenty years, technological advances have accelerated the
liberalizing trend. First videocassettes, and later the Internet, have made
it possible for individuals and couples to enjoy adult entertainment in
private. VCRs have allowed adult entertainment in the privacy of bedrooms.
Advancing Internet technology makes it possible, through filters and
monitoring software, to shield children from adult materials and to protect
adults from exposure to content they might consider offensive.
In fact, families are taking advantage of filtering technology at a
substantial and growing rate. A 2005 survey by the Pew Internet and American
Life Project shows that 54% of Internet-connected families now use some sort
of filter or monitoring software, up from 41% of Internet-connected families
who used filters in 2000. The filters tend to be used by parents who
themselves are frequent users of the Internet and who have middle-school-age
children. Parents who have older children and who are less tech-savvy are
less likely to use filters. Clearly the future is promising for those who
want to shield children and non-consenting adults from sexually-explicit
materials, while at the same time allowing freedom for the private, adult
enjoyment of erotic materials.
In theory, as adult entertainment becomes more personal and private, public
policy should adjust accordingly with less regulation. After all, since
there is no peer-reviewed scientific evidence demonstrating that viewing
sexually-explicit material is harmful, what business is it of government
what form of entertainment adults choose in private? Alas, the current trend
is in the opposite direction. Social conservatives, enjoying a window of
opportunity for their agendas in Washington, would roll back sexual
liberalism in its entirety if they could, from Cable TV to Hollywood films.
Failing that, they seem determined to inflict punishment on individuals
involved in adult entertainment, using obscenity law enforcement. U.S
Attorney General Alberto Gonzales has announced he intends to aggressively
prosecute obscenity cases. Some outspoken conservatives in Congress with
connections to religious fundamentalists are urging him on. The Department
of Justice has already initiated obscenity indictments against large
distributors who sell standard-fare adult entertainment in Main Street adult
video shops.
The problem with using criminal obscenity prosecutions to attack the adult
entertainment industry is that this approach threatens a few individuals
with disproportionately severe punishment -- penalties for obscenity
convictions have been ratcheted up over the years until they are now on a
par with terrorism or armed robbery -- for doing nothing more than providing
entertainment for millions of fully consenting, appreciative adults --
entertainment that is enjoyed in private.
An escalating attack against freedom of expression is also taking place at
state and local levels. Adult entertainment foes use local ordinances in an
effort to block exotic dance clubs and adult stores. Zoning laws often
require adult stores to locate in outlying industrial zones. In spite of
this, local patrons of the clubs and stores remain plentiful and the adult
businesses prosper. Most dance clubs no longer fit the run-down, sleazy
stereotype of yesteryear, but are upscale and thriving, with lots of
customers. What is the justification for laws that discriminate against
clubs and adult stores that serve millions of fully consenting, appreciative
adults, behind closed doors?
V. THE MAINSTREAMING OF ADULT ENTERTAINMENT
The fact that adult entertainment has become widely accepted by Americans
across the nation is the defining basis of this White Paper. There are many
indicators that adult entertainment has entered the mainstream, especially
in recent years. Adult stars appear in mainstream films and on talk shows.
There are best-selling books by adult entertainment personalities. Films
celebrate industry heroes like Larry Flynt.
All this infuriates social conservatives, who understand that the stakes are
high. To put the issue starkly, if adult entertainment is in fact widely
accepted by mainstream populations, then efforts to censor it are clearly
misguided and unfair to both consumers and producers.
Furthermore, if adult entertainment is in fact widely accepted by mainstream
populations, then the use of criminal obscenity law to regulate it is
unconstitutional. In order to decide materials are obscene, according to a
criterion set down by the Supreme Court in Miller v California in 1973, an
average person must consider those materials to be patently offensive by
contemporary community standards. The more people there are who enjoy adult
entertainment, the harder it becomes to make the argument that adult
entertainment is patently offensive to the average person. Social
conservatives contend that adult entertainment and obscenity are virtually
synonymous. They are not -- for the simple reason that the average person
does not find the vast majority of adult entertainment offensive. Quite the
contrary. If “average person” is defined by a statistical median, then the
average person is more likely to enjoy adult entertainment than be offended
by it.
This is true even in the so-called “red states,” as the following examples
document.
Utah County, Utah, is one of the most conservative communities in the
nation, judging from voting records in presidential elections. In a
mid-1990s court case, Randy Spencer, a court-appointed attorney, defended a
Utah County video store whose owner had been charged with 15 counts of
obscenity for renting adult tapes. The prosecutors claimed the store was
violating the community standards of suburban Provo.
Spencer subpoenaed records that showed the following: Utah County cable
subscribers had ordered at least 20,000 explicit movies in the past two
years; a local video store was deriving 20 percent of its rental sales from
adult movies, even though adult movies only made up 2 percent of the store’s
inventory; a nearby adult store was racking up on average $111,000 dollars
per year selling sex toys and other adult fare; and the Provo Marriott,
literally across the street from the courthouse, had sold 3,448 adult
pay-per-view movie rentals in 1998 alone. Spencer won the case.
Another example: In 2001, when prosecutors in ultra-conservative Hamilton
County, Ohio, filed obscenity charges against two local video stores for
selling adult videos, The Cincinnati Enquirer launched an investigation of
community standards.
Wrote the Enquirer:
“In 2000, more than 21,000 Hamilton County residents purchased 26,000
explicit videos from one of the nation’s largest mail-order companies (Adam
& Eve). A company spokeswoman described those sales as typical for a
community of this size…. In January of 2001, 182,000 Greater Cincinnati
residents -- an estimated 70,000 from Hamilton County -- visited an adult
Web site at least once. Nielsen–NetRatings found that 21.8 percent of all
residents in Hamilton County who went online visited an adult site. The
national average per month was 21.4 percent. In 2001 Hamilton County,
residents bought adult movies on pay-per-view TV at about the same rate as
viewers did in other mid-sized TV markets. The numbers suggest county
residents are quiet contributors to the adult industry’s rapid growth. And
with every purchase, they change Hamilton County’s long-held notion of a
community standard.”
The video store owner who fought the obscenity charges in a court trial was
acquitted.
As these examples show, adult entertainment is popular even in conservative
regions of the country. Of course, those who enjoy adult materials often do
not announce themselves. Such matters remain, for many, private and
personal. In addition, adult entertainment fans living in conservative
regions risk being denounced and vilified if they were to reveal their true
tastes. Nonetheless, thanks in major part to the Internet, and to the
anonymity and privacy that the Internet allows, there has been an enormous
increase in the sheer numbers of Americans enjoying adult entertainment --
all over the nation.
And in the larger urban areas, erotic fantasy -- portrayed by adults, for
adults -- no longer carries the weight of shame or fear it once did. At the
same time that millions are partaking of adult entertainment in private,
many others openly celebrate the genre. At AVN’s Adult Entertainment Expo,
which is held every year concurrently with the Consumer Electronics Show in
Las Vegas, attendance is extraordinary. Over 30,000 visitors attended the
2005, four-day convention. Over 22,000 attended the Los Angeles’ Erotica
L.A. convention in June, 2004.
The popularity of adult entertainment was nicely illustrated in 1999 when
the adult section was moved to separate quarters at the East Coast Video
Show. “Mainstream” exhibitors complained strenuously because of the fall off
of interest in their exhibitions.
VI. THE ADULT ENTERTAINMENT INDUSTRY AND HIV
Despite the fact that on-set practices as well as testing programs within
the adult video industry delayed the advent of HIV in performer ranks for
over 15 years, in early 1998 five performers tested positive for the
disease. The impact of this proved to be a wake-up call, as performers and
companies faced the immediate need for a no-nonsense, state of the art HIV
testing program.
Today the adult video industry has just such a program, thanks to the Adult
Industry Medical (AIM) Healthcare Foundation. Founded by Sharon Mitchell,
Ph.D., AIM is in its 6th year of service to the industry (and the general
public) and works cooperatively with the Los Angeles County Health
Department.
In conjunction with the Los Angeles Department of Health Services, AIM has
created a set of guidelines for the adult entertainment industry based on
both County concerns and the wisdom of industry insiders.
Every 30 days, each performer voluntarily tests for HIV by means of the best
test available, the PCR-DNA test. Compliance with the testing regimen is
nearly universal among performers. The artists inspect certified copies of
each other's HIV tests before performances. There are also monthly tests for
chlamydia, gonorrhea and syphilis.
In addition AIM guidelines call for using condoms whenever and wherever
possible, monthly certified counseling as well as notification and treatment
protocols if a performer were to be tested HIV positive. Routine Hepatitis
and STD testing for a wide range of diseases is also recommended and
routinely provided, as well as treatment when required. AIM has over 14
local testing sites in southern California and 40 nationwide. All staff are
counselors certified by the Office of AIDS Policy and Program and by the
County Department of Health Services.
In the spring of 2004, four adult performers contracted HIV, a tragic fact
that resulted in great consternation within the industry and a media
firestorm without. Some called for increased regulation. However, the AIM
system, designed to quickly identify and avoid any spread of the virus,
worked extremely well to contain the spread of HIV during the emergency. As
soon as the infection was discovered, the agency declared a moratorium on
all productions until all potentially infected persons could be found,
quarantined and tested.
As a result of the measures taken under the AIM protection system, the
outbreak was contained to those initial four cases. In addition, it is now
standard within the industry to quarantine all new performers, and all
performers returning from working abroad. Moreover, AIM has worked with
adult video producers to create a database of sex scenes which is updated
each day, so that performers can be notified of potential health risks
within hours, and if necessary, quarantined to protect their health.
The industry-wide response to the 2004 HIV outbreak points to the maturity
of the adult entertainment industry and the strong sense of responsibility
most members of the industry feel toward talent and the health risks
performers may face in doing their work. Because of industry support, AIM,
in cooperation with FSC, was able to halt the spread of infection within the
industry and protect the interests of the general public who might come into
contact with infected performers.
VII. FSC AND PUBLIC POLICY
As the trade association for the adult industry, Free Speech Coalition seeks
to influence public policy through education, lobbying and -- as a last
resort -- litigation.
Education
Free Speech Coalition works to correct misinformation and stereotypes about
adult entertainment, providing testimony in the legislative process and
being available for interviews in the media. FSC issues press releases,
organizes public events, and provides written information such as that
contained in this White Paper. FSC maintains a library of information,
research data, briefs on new and pending legislation and documents
concerning historical legal findings and precedents.
Lobbying
Historically, adult entertainment has been regulated with insufficient
dialogue between regulators and the industry being regulated. Until recent
years, there was no recognized voice for the industry as a whole, other than
an occasional lawyer representing an affected business. In recent years that
pattern has changed dramatically. Free Speech Coalition currently employs
lobbyists in Sacramento and in Washington, D.C. FSC also coordinates
lobbying efforts with local FSC chapters and with Association of Club
Executives (ACE) chapters throughout the country. (ACE is a trade
association for the adult nightclub industry.)
FSC also conducts an annual training program to educate members from all
sectors of the industry in the political process. With support and
supervision by FSC’s Legislative Affairs Director Kat Sunlove, small groups
of adult industry citizen lobbyists meet with California State legislators
and staff to discuss issues related to adult entertainment. The process has
proven beneficial on both sides. The industry lobbyists gain a better
understanding of the political process; and legislators and staff gain a
better understanding of the adult industry.
Litigation
FSC enters into litigation when the issues involved are likely to set
precedent or have an effect on the entire adult entertainment industry. For
example, the U.S. Supreme Court decision in Ashcroft v. Free Speech
Coalition (2002) overturned federal law that would have criminalized adult
actors portraying underage characters in erotic scenes, both in adult
entertainment and in mainstream materials.
Currently, FSC has targeted certain sections of 18 U.S.C. § 2257 (the
Federal Record-keeping and Labeling law) for litigation. Even in its earlier
form, FSC had serious concerns about the 2257 law. However, the law was
recently “clarified” by the U.S. Department of Justice in a way that will
make compliance very difficult, if not impossible, for any adult
manufacturer, producer, content provider or website operator. As soon as the
final regulations are announced and become official, Free Speech Coalition
plans to seek a court injunction against the law on behalf of FSC and its
members.
Thank you for your time in considering our positions. If you have any
comments or questions, please feel free to contact Executive Director
Michelle L. Freridge at the offices of the Free Speech Coalition, (866)
372-9373.
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