18 U.S.C. 2257 Statement

Sexual depictions of persons that SPKI inc. includes in what the Service provides are not photographs of real persons but expressions of fictional adults generated by AI. The Service does not film or record sexual conduct by actual performers, and output that sexually depicts a real person is not included in what is provided. A realistic appearance of a person does not mean that there is a real performer.

The statement that we "do not depict real persons" assumes a policy and controls limited to sexual output of a lawful fictional adult that is fully synthesized and is not based on the image, face, or identifiable features of a real person. It is not an unverified guarantee that every item of data, including a user's violating input, a chance resemblance, or a failure of review, is absolutely unrelated to a real person.

On the premise that the fully synthesized output covered by the preceding Article has no real performer and that we do not produce, edit, or publish actual or simulated sexually explicit conduct of a real person, our position is that, as to that output, we are not a primary producer or a secondary producer within the meaning of 18 U.S.C. §§2257 and 2257A and 28 C.F.R. Part 75.

This is not a claim that AI is automatically exempt. Those provisions can also cover a computer-manipulated image of a real person, so the conclusion depends on the actual processing, whether a person is identifiable, the material used, and the business activity. Being a Delaware corporation is not itself a reason for an automatic exemption.

A sexual deepfake, nudification, face swap, sexual generation using one's own likeness, and combination with sexual material of a real person are prohibited even with consent. This statement does not warrant the legality of such content or an exemption from record-keeping. Where an image of a real person is handled as a non-sexual reference input, confirmation of adulthood, rights, and consent follows the Terms of Service and the Age Verification Policy separately.

If something suspected of being a sexual depiction of a real person is found, provision is blocked immediately and U.S. counsel confirms any record-keeping, reporting, and preservation duties. If we later change to handling covered content of a real person, that provision does not begin until performer identity and age verification, record-keeping, display and inspection arrangements, and amendment of the terms are complete.

Even for a synthetic person, a sexual depiction of a minor or of a person who appears to be a minor, CSAM, non-consensual sexual content, and any other breach of the Acceptable Use Policy are not permitted at all. A conclusion about 2257 is not an exemption from criminal law, child-protection law, portrait rights, privacy law, or card rules. Blocking, necessary preservation, and a lawful report to NCMEC and the authorities follow the Under-18 Protection Policy.

Contact: SPKI inc., Attn: Oliver Bennett, 131 Continental Dr Suite 305, Newark, DE 19713, US. support@mydrm.ai.

We do not state that we have created an identity document or records for a performer who does not exist. Ordinary age-verification records and statutory 2257 records about performers are separate.

Established: August 16, 2026. Last updated: November 8, 2026. Effective date: November 8, 2026. Version 1.

A change that operates as a contract term follows the procedure in Terms of Service Article 2, and any required individual consent is obtained separately.

Operator: SPKI inc. Inquiries: support@mydrm.ai. Please read together the Terms of Service, the Acceptable Use Policy, the Refund Policy, the Complaints Policy, the Privacy Policy, the Cookie Notice, the DMCA Policy, the 18 U.S.C. 2257 Statement, the Age Verification Policy, the Under-18 Protection Policy, the Anti-Slavery and Human Trafficking Statement, and the Specified Commercial Transactions Act Disclosure.