18 USC 2257 Record-Keeping Requirements Compliance Statement

BN Media, LLC. ("BN Media") is a company which provides affiliate advertising services via a number of adult-oriented websites ("Our Websites") engaged in activities which enjoy vast First Amendment protection since adult-oriented expression that does not depict children is presumptively protected by the First Amendment of the United States Constitution.

BN Media provides distribution, advertising, and editorial services for a large number of adult-oriented websites for which BN Media is neither a "primary producer" or "secondary producer".  As a distributor of  advertising content, BN Media is exempt from some of the requirements of 18 USC 2257 since according to 28 C.F.R. 75.1(c)(4)(ii), "producer" does not include persons whose activities relating to the visual depiction of actual sexually explicit conduct are limited to "mere distribution."  As an advertiser, BN Media is exempt from some of the requirements of 18 USC 2257 since 28 C.F.R. 75.1(c)(4)(iii), exempts "[a]ny activity, other than those activities identified in paragraphs (c) (1) and (2) of this section (28 C.F.R. 75.1), that does not involve the hiring, contracting for, managing, or otherwise arranging for the participation of the depicted performers." and since 28 C.F.R. 75.1(k) exempts BN Media as an advertiser under the "Manager" definition of a "secondary producer" since "Manage content ... does not mean those who manage solely advertising, compliance with copyright law, or other forms of non-sexually explicit content."

In regards to any content on any sites owned and operated by BN Media, the following statements apply:

Donald E. Chase
BN Media, LLC.
8 Front Street, Suite 303
Salem, MA 01970

Due to the fact that BN Media, LLC. is a small business with one owner (The Custodian), who is also employed outside of the capacity of being The Custodian for Our Websites, the hours during which The Custodian is available are varied on a day-by-day and week-by-week basis.  In no case is The Custodian available to provide compliance inspections less than 20 hours per week during "regular working hours and at other reasonable times".

Last Revised June 22, 2005