Draft pending legal review
2257 Compliance Statement
# 18 U.S.C. 2257 Compliance Statement
> DRAFT - not legal advice; review by qualified counsel before publication.
> Bracketed tokens such as [OPERATOR LEGAL NAME], [OPERATOR RECORDS ADDRESS],
> [JURISDICTION], [EFFECTIVE DATE], and [OPERATOR ABUSE EMAIL] are placeholders
> to be completed by the operator and its counsel.
Effective date: [EFFECTIVE DATE]
## 1. Purpose and context
This statement is provided in the manner of 18 U.S.C. 2257 and 2257A and 28 C.F.R.
Part 75. [OPERATOR LEGAL NAME] operates an adults-only AI companion platform (the
"Service").
All characters appearing on the Service are entirely synthetic, fictional, computer-
generated personas. They are not real human beings and do not depict any actual
person, living or dead. No real performers are used. The Service has no mechanism by
which a photograph, video, audio recording, or other likeness of any real person can
be uploaded or introduced; companion appearance is generated from text descriptors and
any voice is synthetic.
Because the content does not depict actual human beings engaged in any conduct,
[OPERATOR LEGAL NAME]'s position is that the federal recordkeeping requirements that
apply to depictions of real performers are not triggered by wholly computer-generated
characters. Counsel should confirm the applicability of 18 U.S.C. 2257, 2257A, and 28
C.F.R. Part 75 to the operator's specific offering and jurisdiction.
Notwithstanding the foregoing, and as a matter of good-faith compliance and
transparency, [OPERATOR LEGAL NAME] voluntarily maintains the records described below
to document the synthetic, AI-generated nature of all content and to evidence that no
real person is depicted.
## 2. Custodian of Records
The Custodian of Records for content made available on the Service is:
[OPERATOR LEGAL NAME]
Custodian of Records
[OPERATOR RECORDS ADDRESS]
Contact: [OPERATOR ABUSE EMAIL]
The Custodian of Records maintains the records described in Section 3 and is the point
of contact for lawful records inspection requests. [Counsel to confirm the named
individual custodian, business hours for inspection, and any agent-for-service
requirements.]
## 3. Records maintained
For each generated image and any age-restricted media produced through the Service,
[OPERATOR LEGAL NAME] maintains the following records, generated and stored by the
platform's guarded generation pipeline:
3.1 Generation records (the generation_records set). Each record documents:
- the generation type (for example, avatar, scene, nude reference, or video);
- a cryptographic hash of the generation prompt (prompt_hash);
- cryptographic hashes of any reference assets used (reference_hashes);
- a content-provenance manifest reference where available (for example, a C2PA
Content Credentials manifest URL);
- whether the requesting adult user provided an attestation; and
- the relevant timestamps.
3.2 Generation attestations (the generation_attestations set). For age-restricted
media, each record documents the adult user's per-generation attestation that the
character is a fictional character and not a real person, the associated user
identifier, a salted hash of the originating IP address (ip_hash, not a raw IP), and
the timestamp.
These records reference synthetic, AI-generated characters and document the absence of
any real performer. Because the Service does not collect identity documents of any
performer (there is no performer), no such documents are held; the records instead
establish the computer-generated provenance of the content.
## 4. Age and eligibility controls
4.1 The Service is restricted to users who are at least 18 years of age (or the age of
majority in their jurisdiction, if higher).
4.2 Adult eligibility is confirmed through a third-party age-verification vendor.
[OPERATOR LEGAL NAME] stores only an opaque verification reference and status; it does
not store the user's identification document.
4.3 The platform enforces a synthetic-content adult-representation gate on generated
media. This control fails closed: media that is not assessed as clearly depicting an
adult character is blocked and not made available. This is an additional safeguard to
ensure that no content even appears to depict a minor, consistent with the prohibition
in the Acceptable Use Policy and applicable law (including 18 U.S.C. 2256 and 1466A).
## 5. No depiction of minors or real persons
[OPERATOR LEGAL NAME] strictly prohibits, and the platform is designed to prevent, any
content that depicts or appears to depict a minor, and any content depicting a real,
identifiable person. Attempts to elicit such content are blocked by automated controls
and may result in account termination and referral to authorities as required by law.
## 6. Recordkeeping integrity and retention
The generation records and attestations described in Section 3 are written by the
platform's server-side (service-role) processes only and are not user-editable. They
are retained for the period required by applicable law and the operator's retention
schedule. See the Privacy Policy for related data-handling details.
## 7. Inquiries
Records inspection inquiries and other questions regarding this statement may be
directed to the Custodian of Records at [OPERATOR RECORDS ADDRESS] or
[OPERATOR ABUSE EMAIL].