Shorter 18 U.S.C. § 2257 EXEMPTION STATEMENT
Statement of Exemption
WT Publishing LTD (the "Company", "we", "us") operates the Shorter website, mobile application and associated services (the "Platform"), which distribute short-form, episodic fictional entertainment intended for adult audiences only.
The record-keeping, labelling and inspection requirements of 18 U.S.C. § 2257, 18 U.S.C. § 2257A and 28 C.F.R. Part 75 (together, the "Record-Keeping Requirements") apply to producers of visual depictions of actual human beings engaged in actual or simulated sexually explicit conduct, as defined in 18 U.S.C. § 2256(2). Those requirements do not apply to the content made available on the Platform, for two independent reasons: no actual human being is depicted in it, and it does not depict sexually explicit conduct.
Basis for the Exemption
No actual human beings are depicted. All content on the Platform:
(a)is fictional, and is created by the Company's in-house studio with the assistance of generative artificial intelligence;
(b)depicts only characters that are entirely computer-generated — no performer, model or other real person is recorded, filmed, photographed or otherwise depicted; and
(c)does not use the face, body, likeness or voice of any real person, living or deceased, as a generative or likeness reference.
No sexually explicit conduct is depicted. The content may contain mature themes, partial or full nudity, and depictions of sexual activity of a non-explicit, softcore nature. The content does not contain explicit or close-up depiction of genital contact, penetration, or sexual acts of a pornographic nature.
Because no actual human being is depicted in any content on the Platform, there are no performers whose identity or age must be verified, and no records of that kind exist or are required to be maintained.
No User-Generated Content
The Platform does not allow users to upload, submit, embed, stream or otherwise publish content. All content is originated, produced and controlled exclusively by the Company and is published only after it has passed every stage of the review described in our Content Monitoring Policy.
Adult Audience and Character Standards
The Platform is intended for adults aged 18 and over. The Company prohibits any depiction of a person under the age of eighteen (18), or of any character who is, is represented as, or could reasonably be perceived as being under the age of eighteen, in any sexual, suggestive or nude context. As an internal safeguard exceeding the legal threshold, the Company requires that all characters appearing in the content be scripted, designed and rendered as adults aged twenty-one (21) years or older.
Contact
Questions about this statement, or reports of content you believe to be unlawful or in breach of our policies, can be sent to support@shorter.tv.