xxxjay: You are correct. Any advice given around here is on a "what I think it is" point of view. Contacting a lawyer and getting their advice and working within guidelines they provide is always the best thing.
That being said, there are a ton of questions out there that can be pretty much answered by a plain reading of the rules as published, and this can encourage people to start to work on the things they will need to get things done.
grandmasscrotum: You said "I also think this is one of the bits the lawyers will fight over. "A prudent secondary producer"??" - you have to remember that while there is a whole preamble and discussion of comments received as so on, that is truly not the rules just commentary. The real rules are further down the document and those are the things you need to truly be concerned with. The rest is a narrative that can help you understand what the rules say, but the rules themselves and the wording of those rules are the only things that can truly matter. The guidance provided by the preamble is great, however, at making it easier to understand the DOJ's intent regarding this new rules.
Alex
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