18 U.S.C. §§ 2257 & 2257A Compliance Statement
Last updated: July 12, 2026
1. Purpose
This statement explains how the Komicha service, operated by KMC Holding LLC, relates to the record-keeping requirements of 18 U.S.C. § 2257 (actual sexually explicit conduct), 18 U.S.C. § 2257A (simulated sexually explicit conduct), and 28 C.F.R. Part 75.
2. Basis for Exemption
All visual depictions on Komicha are exempt from the record-keeping provisions of 18 U.S.C. §§ 2257 and 2257A and 28 C.F.R. Part 75 because:
- they are exclusively artificial creations generated by artificial intelligence in an illustrated, comic-panel style;
- they do not portray any actual human being, and no human models, performers, actors, or actresses were used, photographed, or filmed in the creation of any depiction on the service;
- because no depiction involves an actual human being engaged in actual or simulated sexually explicit conduct, KMC Holding LLC is not a “producer” of any such depiction as defined in 18 U.S.C. § 2257(h)(2) and 28 C.F.R. § 75.1(c).
3. Our Practices
Although the statutory record-keeping obligations do not apply, Komicha:
- prohibits any content depicting real, identifiable people anywhere on the service, including in generation inputs (see our Content & Acceptable Use Policy);
- prohibits absolutely any content that sexualizes minors, including fictional depictions, and reports apparent child sexual abuse material to NCMEC as required by federal law;
- restricts the service to adults 18 and older;
- retains generation records for content produced by the service and cooperates promptly with lawful requests from governmental authorities.
4. Contact
Questions regarding this statement may be directed to legal@komicha.com.