as child pornography. In 2002, FSC views were upheld in the US Supreme Court in Ashcroft v. Free Speech Coalition, the "virtual child porn" case. In 2005, FSC filed a complaint against the Dept of Justice and then-Attorney General Alberto Gonzales, citing that 18 U.S.C. § 2257 regulations endangered the privacy and safety of performers by allowing private information to be accessed through the record-keeping process; also that 2257 regulations were complicated to the extent that adult producers would be unable to fully comply with the record-keeping system. The controversial regulations have been an ongoing issue for adult industry producers and FSC. In February 2009, the United States Court of Appeals for the Sixth Circuit held in Connection Distributing Co. v. Holder that the record-keeping provisions of 18 U.S.C. § 2257 did not violate the First Amendment. A revised set of the § 2257 regulations was released in December 2009, prompting another complaint against the DOJ and Attorney General Eric Holder in 2010. California porn tax The FSC entered the field of lobbying in earnest in 1994, with the retention of a lobbyist in Sacramento, California's state capitol. After a year, the lobbying presence proved itself critical for the health of the national industry. A tax bill was introduced, with the purpose of assisting victims of domestic abuse and rape. An excise tax was proposed for all adult products and services, with the proceeds going to collection of the tax, law enforcement and, if anything remained, to rape counseling centers and battered victim shelters. Constitutional law had long forbade the targeting of a content-defined tax and this bill was the model of such a tax scheme. Traditionally the industry had relied solely on the judiciary to protect itself against such intrusions, and legislatures across the country have become accustomed to regulating the adult industry without consultation with the parties to be regulated. Both patterns came to a halt with this proposed tax. The FSC led a coalition of affected businesses and industry groups in fighting the tax. The FSC argued that the tax was a dangerous, unconstitutional precedent and that it would be bad for the state's economy. During the course of the ensuing debate, the economic influence of the adult entertainment industry was established in the minds of the zero votes in support. The bill was defeated at its first committee hearing. Performer Availability Screening Services PASS (Performer Availability