§ 2257 Statement

Last Updated: September 13, 2026

Platform Architecture and Content Posture

Seconds is an end-to-end encrypted, one-to-one video calling service. It is not a content platform: it hosts no content library, no catalog, no archive, and no recorded material of any kind, and it offers no facility by which any user could upload, publish, browse, purchase, stream, download, or replay a recording of a call.

Video and audio of a call are encrypted on each participant's device using WebRTC with DTLS-SRTP. The encryption keys are negotiated directly between the two participants' devices and are never transmitted to, held by, or accessible to Seconds. So that neither participant learns the other's IP address, the encrypted media stream is forwarded through a third-party TURN relay rather than over a direct connection between the two devices; that relay forwards encrypted packets, does not hold the encryption keys, cannot decrypt the media it carries, and does not retain it. Seconds operates no media server and no recording, transcoding, archival, or scanning infrastructure in the media path. Call content is therefore not recorded, stored, hosted, processed, analyzed, or otherwise managed by Seconds or its infrastructure, and Seconds has no technical capability to do so. Seconds does not act as a producer of any visual depiction transmitted during a call within the meaning of 28 C.F.R. § 75.1(c).

The only visual depictions that Seconds hosts are user-supplied profile photographs. Seconds' content policies prohibit profile photographs that depict sexually explicit conduct as defined in 18 U.S.C. § 2256(2)(A), including: (i) sexual intercourse; (ii) bestiality; (iii) masturbation; (iv) sadistic or masochistic abuse; or (v) lascivious exhibition of the anus, genitals, or pubic area. Nudity and sexual solicitation are likewise prohibited. These policies are enforced through human moderation: every image uploaded to the platform enters a moderation queue in which a human reviewer approves, flags, or removes it, and every such decision is written to an immutable review history. A profile photograph that violates this policy is removed, is thereafter hidden from every public surface of the platform, and the responsible account is subject to suspension or termination.

Exemption from § 2257 Record-Keeping Requirements

Based on the foregoing, Seconds claims exemption from the record-keeping requirements of 18 U.S.C. § 2257 and 28 C.F.R. Part 75 with respect to all visual depictions on the platform because:

• Video calls transmitted via Seconds are not visual depictions hosted, managed, or produced by Seconds. They exist transiently between two consenting adults and are protected by end-to-end encryption that Seconds cannot decrypt, using keys Seconds never receives. Seconds operates as a transmission service and is not a producer (primary or secondary) of any call content within the meaning of 28 C.F.R. § 75.1(c).
• Profile photographs hosted on Seconds do not depict conduct enumerated in 18 U.S.C. § 2256(2)(A)(i) through (v), consistent with platform policy and active moderation. Seconds does not act as a producer of such exempt images as that term is defined in 28 C.F.R. § 75.1(c).
• Seconds does not produce, create, alter, digitize, or otherwise modify any visual depiction of sexually explicit conduct in connection with its services.

Adult Verification

All Creators registered on Seconds complete identity verification through a third-party identity verification provider, confirming that each Creator is at least eighteen (18) years of age at the time of registration. That check is not the only gate: an account cannot become a Creator unless it has both passed third-party identity verification and been approved by a human reviewer at Seconds. Neither requirement can be bypassed, and an account that fails either one cannot offer services, receive calls, or be paid. Fans are not subject to third-party identity verification: before a fan can place a call they must record a date of birth establishing that they are at least eighteen (18) years of age, which Seconds validates and enforces server-side.

Defense-in-Depth Records

Notwithstanding the exemption claim above, in the event that any visual depiction on Seconds is later determined to fall within the scope of 18 U.S.C. § 2256(2)(A) and to be subject to § 2257 record-keeping requirements, Seconds maintains identity verification records for each Creator linked to images uploaded by that Creator. These records are maintained by the Records Custodian designated below and are available to authorized inspectors during regular business hours pursuant to 28 C.F.R. § 75.5.

Records Custodian

The title of this work is: Seconds.

Records Custodian: Seconds Inc.
Address: 251 Little Falls Drive, Wilmington, DE 19808, United States
Email: hello@seconds.me

Reporting Concerns

To report content believed to violate platform policies or applicable law, including content believed to depict minors or to have been produced or shared without consent, please contact abuse@seconds.me. Seconds investigates all reports and cooperates with law enforcement pursuant to valid legal process.