18 U.S.C. 2257 Exemption

Effective date: 22 June 2026
Last updated: 22 June 2026

This statement explains why Go Girlfriend ("Go Girlfriend", operated by First Kind AI Inc., "we", "us" or "our") is exempt from the federal record-keeping requirements of 18 U.S.C. 2257 and 18 U.S.C. 2257A and their implementing regulations at 28 C.F.R. Part 75.

1. What the law requires

The record-keeping and labelling obligations of 18 U.S.C. 2257 and 2257A apply to "producers" of certain visual depictions of actual human beings engaged in actual (or, in the case of 2257A, simulated) sexually explicit conduct. Those provisions require producers to create and maintain records verifying the legal age and identity of every real performer depicted, and to post a compliance statement disclosing where those records are kept.

2. Why Go Girlfriend is exempt

The statutory triggers for 18 U.S.C. 2257 and 2257A are not present on Go Girlfriend. Specifically:

• All characters, personas and companions offered through Go Girlfriend are entirely fictional and are computer-generated and AI-generated. They do not depict, portray or reproduce any real, identifiable person.
• No real person is depicted in any sexually explicit conduct, and the service contains no sexually explicit visual content. Companion images are AI-generated and do not depict any real, identifiable person. Companion replies are AI-generated text voiced by text-to-speech; the underlying voice models are licensed, with consent, from professional adult voice actors engaged for ordinary, non-explicit voice work.
• Go Girlfriend is a platonic AI companion chat service. It does not contain visual depictions of actual sexually explicit conduct involving any real person, and it is not in the business of producing such depictions.

Because the service contains no visual depictions of actual human beings engaged in actual sexually explicit conduct, it falls outside the scope of 18 U.S.C. 2257 and 2257A. Accordingly, Go Girlfriend is exempt and is not required to maintain 2257 or 2257A records. The voice actors we engage are adults contracted for non-explicit voice work, which is outside the scope of these record-keeping provisions.

3. Affirmation regarding depicted personas

All companions and personas presented on Go Girlfriend are fictional and are intended and represented to be adults aged 18 or over. We do not knowingly create, host or permit depictions of minors, and child sexual abuse material is strictly prohibited. We report apparent child sexual exploitation to the National Center for Missing and Exploited Children (NCMEC) as required by US law. Use of Go Girlfriend is restricted to persons aged 18 and over, as set out in our Terms & Conditions and Acceptable Use Policy.

4. Scope and good faith

This statement is provided in good faith to describe the nature of our service accurately. It is a factual explanation of why the cited record-keeping provisions do not apply to AI-generated content and is not a representation that we are subject to those provisions. Nothing in this statement creates obligations beyond those imposed by applicable law. If the nature of the service materially changes, we will review and update this statement.

5. Related policies

This statement should be read together with our Terms & Conditions, Acceptable Use Policy, Content Removal Policy and DMCA Policy.

6. Contact

Questions about this exemption statement, or general assistance, may be directed to [email protected].