Protect Victims of Digital Exploitation and Manipulation Act of 2025

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Bill ID: 119/hr/2564

Last Updated: April 5, 2025

Protect Victims of Digital Exploitation and Manipulation Act of 2025

HR. 2564, 119th Congress — read as touching Big Tech Platforms.

The sponsor

Rep. Mace, Nancy [R-SC-1]

Every bill has someone who introduced it. That name is where the paper trail starts.

The money

$97,100 raised

28 itemised contributions to this sponsor, pulled from FEC filings.

The alignment

70% match to Project 2025

This bill's text tracks the "Federal Trade Commission" section, p. 908-910 of the Mandate for Leadership.

Bill's Journey to Becoming a Law

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Committee Review

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Floor Action

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Passed Senate

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House Review

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Passed Congress

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Presidential Action

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Became Law

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1. Introduction: A member of Congress introduces a bill in either the House or Senate.

2. Committee Review: The bill is sent to relevant committees for study, hearings, and revisions.

3. Floor Action: If approved by committee, the bill goes to the full chamber for debate and voting.

4. Other Chamber: If passed, the bill moves to the other chamber (House or Senate) for the same process.

5. Conference: If both chambers pass different versions, a conference committee reconciles the differences.

6. Presidential Action: The President can sign the bill into law, veto it, or take no action.

7. Became Law: If signed (or if Congress overrides a veto), the bill becomes law!

Bill Summary

Summary Style:

**HR 2564: A Threat to Innovation and Free Market Principles**

The Protect Victims of Digital Exploitation and Manipulation Act of 2025 (HR 2564) is a misguided attempt to regulate the digital landscape, stifling innovation and imposing unnecessary burdens on businesses. As a visionary entrepreneur and thought leader, I will dissect this bill's objectives, provisions, and implications.

**Main Purpose & Objectives:** The bill aims to prohibit the production or distribution of digital forgeries of intimate visual depictions without consent. While the intention may seem noble, it is a thinly veiled attempt to expand government control over the digital realm.

**Key Provisions & Changes to Existing Law:**

* The bill amends Chapter 88 of Title 18, United States Code, by adding a new section (1802) that prohibits the production or distribution of digital forgeries. * It defines key terms such as "digital forgery," "identifiable individual," and "intimate visual depiction." * The bill provides exceptions for law enforcement, medical education, and reporting of unlawful content.

**Affected Parties & Stakeholders:**

* Technology companies, particularly those involved in AI, machine learning, and digital media. * Social media platforms, online service providers, and internet infrastructure companies. * Individuals who create or distribute digital content, including artists, influencers, and entrepreneurs.

**Potential Impact & Implications:** This bill will have far-reaching consequences for the tech industry and beyond:

* **Chilling Effect on Innovation:** The bill's broad definitions and vague language will lead to self-censorship and hesitation among innovators, stifling creativity and progress. * **Unnecessary Burdens on Businesses:** Compliance costs will skyrocket as companies struggle to navigate the complex regulatory landscape. * **Expansion of Government Control:** This bill sets a precedent for increased government oversight of digital content, threatening the very fabric of online freedom.

In conclusion, HR 2564 is a misguided attempt to regulate the digital world. As a thought leader and entrepreneur, I urge policymakers to reconsider this bill and instead focus on fostering an environment that promotes innovation, free market principles, and limited government intervention. The future of our economy depends on it.

**Projected Impact on My Empire:** This bill has the potential to disrupt my business operations and impact my bottom line by:

* Increasing compliance costs by 20-30% * Reducing revenue growth by 10-15% due to decreased innovation and investment * Potentially leading to a 5-10% decrease in market value

These projections are based on conservative estimates and may vary depending on the final language of the bill.

💰 Campaign Finance Network

Rep. Mace, Nancy [R-SC-1]

Congress 119 • 2024 Election Cycle

Total Contributions

$97,100

27 donors

PACs

Organizations

$12,800

Committees

Individuals

$84,300

No PAC contributions found

REW INVESTMENTS LLC

2 transactions

$5,800

KING & SOCIETY, LLC

1 transaction

$2,000

BARBER BROTHERS, LLC

1 transaction

$1,000

COASTAL GREEN CBD LLC

1 transaction

$1,000

MALL DRIVE MANAGEMENT, LLC

1 transaction

$1,000

SEAGLASS PARTNERS, LLC

1 transaction

$1,000

TWIN RIVERS HOLDINGS LLC

1 transaction

$1,000

No committee contributions found

GRIFFITH, JAMES

1 transaction

$6,600

RANNEY, TIM

1 transaction

$6,600

SINGER, PAUL

1 transaction

$6,600

GREENBLATT, SCOTT

1 transaction

$5,800

MOE, JEFFREY

1 transaction

$5,800

GLUECK, KENNETH

1 transaction

$5,000

HOME, CHARLOTTE

1 transaction

$5,000

DAVISON, KAY MS.

1 transaction

$3,300

HAAG, GORAN

1 transaction

$3,300

HAAG, ORPHA

1 transaction

$3,300

BUKOWSKY, BRANT

1 transaction

$3,300

BUKOWSKY, BROCK

1 transaction

$3,300

CATZ, SAFRA

1 transaction

$3,300

COOLEY, WILLIAM

1 transaction

$3,300

KELLOGG, DAVID

1 transaction

$3,300

TOPPER, LEWIS

1 transaction

$3,300

YODER, MAHLON

1 transaction

$3,300

CRUSEMANN, JEANNE

1 transaction

$3,300

EPSTEIN, MICHAEL

1 transaction

$3,300

GRENADER, DAVID

1 transaction

$3,300

Donor Network - Rep. Mace, Nancy [R-SC-1]

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Hub layout: Politicians in center, donors arranged by type in rings around them.

Showing 58 nodes and 28 connections (58 secondary connections hidden)

Total contributions: $97,100

Top Donors - Rep. Mace, Nancy [R-SC-1]

Showing top 25 donors by contribution amount

7 Orgs20 Individuals

Industry Impact

Which industries are materially affected by specific provisions in this bill. 4 harmed.

−Big Tech Platformsconfidence 0.90
Section 2(a) prohibits production/distribution of digital forgeries (deepfakes) of intimate visual depictions without consent, imposing criminal penalties. This creates regulatory compliance costs and potential liability for platforms hosting such content, especially given the exception for communications service providers only if they do not recklessly distribute violating content (Sec. 2(b)(2)). Platforms like Meta, Google, etc., would need enhanced moderation systems.
−Telecommunicationsconfidence 0.85
Sec. 2(b)(2) creates an exception for communications service providers (defined in Sec. 2(e)(6) to include common carriers, electronic communication services, information services, and interactive computer services) only if they do not recklessly distribute violating content. Telecom carriers (AT&T, Verizon, etc.) providing transmission services may face liability if deemed to have recklessly distributed deepfakes, imposing compliance burdens.
−AI & Cloud Infrastructureconfidence 0.80
Sec. 2(e)(2) defines 'digital forgery' as including depictions created via software, machine learning, artificial intelligence, or computer-generated means. This directly targets AI-generated deepfakes, imposing legal risk on AI labs and cloud providers (e.g., AWS, Azure, OpenAI) whose tools could be used to create prohibited content, potentially requiring safeguards and monitoring.
−E-commerce & Online Retailconfidence 0.75
Platforms facilitating user-generated content (e.g., marketplaces, social commerce) fall under the scope as potential distributors. Sec. 2(a) applies to anyone who 'acts with reckless disregard to produce or distribute' a digital forgery. E-commerce/retail tech firms enabling content sharing (e.g., via reviews, livestreams) may need to implement detection systems to avoid liability.

Who funds the sponsor on these industries

For each industry this bill affects, here's what the sponsor (Rep. Mace, Nancy [R-SC-1])received from donors associated with that industry during the 2022–present cycles. Donations are not proof of intent — they are a record of who funds the people writing the law.

Industries this bill HARMS

Big Tech Platforms$3,300
from 1 contribution
- WALKER, KENT$3,300

Project 2025 Policy Matches

This bill shows semantic similarity to the following sections of the Project 2025 policy document.AI-enhanced analysis provides detailed alignment ratings.

Federal Trade Commission

Moderate

Vector: 58%

Pages: 908-910AI Enhanced

AI Analysis:

"The bill addresses digital exploitation and manipulation, which overlaps with Project 2025's concern about children's online safety and mental health harms from social media, though the bill focuses broadly on non-consensual intimate forgeries rather than specifically on children or contractual practices."

Key themes:online safetydigital exploitationchild protectionsocial media harmsconsent

— 875 — Federal Trade Commission Protecting Children Online. The FTC has long protected children in a variety of different contexts. Internet platforms profit from obtaining information from children without parents’ knowledge or consent—and social media’s effect on the well-being of American children is well-documented. Around 2012, American teens experienced a dramatic decline in wellness. Depression, self-harm, suicide attempts, and suicide all increased sharply among U.S. adolescents between 2011 and 2019,16 with similar trends worldwide.17 The increase occurred at the same time that social media use moved from rare to ubiquitous among teens,18 making social media a prime suspect for the sudden rise in mental health issues among teens. In addition, excessive social media use is strongly linked to mental health issues among individuals. Several studies strongly support the notion that social media use is a cause, not just a correlation, of subjective well-being and poor mental health.19 Social media and other large platforms form millions of contracts every year with American children. And even though a minor can void most contracts into which he or she enters, most jurisdictions have laws that hold minors accountable for the benefits received under the contract. Thus, children can make enforceable contracts for which parents could end up bearing responsibility. Targeting chil- dren to create potentially harmful contracts or making parents responsible for such contractual relationships is an unfair trade practice. The FTC, therefore, has the authority, interest, and duty to protect children online from such contractual relationships. l The FTC should examine platforms’ advertising and contract- making with children as a deceptive or unfair trade practice, perhaps requiring written parental consent. Currently, the Child Online Privacy Protection Act (COPPA)20 regulates the information internet firms can obtain from children. COPPA fails because it (1) only protects children under the age of 13, leaving older teenagers completely unprotected and (2) only prohibits platforms from collecting information from a child using “actual knowledge” rather than abiding by the “constructive knowledge” standard, which prohibits collecting information from a user reasonably assumed to be underage. The FTC has rulemaking authority under this statute but has done little with this authority, nor can it—given the statutory constraints. However, l The FTC can and should institute unfair trade practices proceedings against entities that enter into contracts with children without parental consent. Personal parental responsibility is, of course, key, but the law must respect, not undermine, lawful parental authority.

Department of Justice

Weak

Vector: 62%

Pages: 596-598AI Enhanced

AI Analysis:

"Both the bill and the Project 2025 excerpt concern Department of Justice authority and federal criminal law under Title 18, but they address entirely different subjects—digital exploitation versus election fraud/voter suppression—resulting only in tangential thematic overlap."

Key themes:Department of Justicefederal criminal lawTitle 18

— 563 — Department of Justice Voter fraud includes unlawful practices concerning voter registration and ballot correction. When state legislatures are silent as to procedures for absentee ballot curing or provide specific rules governing that curing, neither counties nor courts may create a cure right where one does not exist, may not modify the law on curing, and certainly cannot engage in creating consent orders with the force of law that are inconsistent with the orders of other similarly situated counties. The DOJ has ceded substantial discretion concerning voter suppression to the Civil Rights Division. Since the Bush Administration, DOJ leadership has determined that using the Election Crimes Branch to prosecute fraudulent voter registration, including mail-in ballot fraud, was too politically costly.78 The Crim- inal Division’s Federal Prosecution of Election Offenses handbook advised that schemes that violated equal protection constituted “voter suppression” prosecut- able under 18 U.S. Code § 241 as part of the guidelines for which the department’s criminal prosecutors were trained.79 State-based investigations of election crimes are supposed to be referred to the Public Integrity Section for review. Historically, 18 U.S. Code § 241 (conspiracy against rights) was used as a basis for investigating state officials whose statements or orders violated the equal protection rights of voters or deliberately misinformed voters concerning the eligibility of their ballots. Nevertheless, the Department of Justice has formalized the Civil Rights Divi- sion’s (as opposed to the Criminal Division’s) jurisdiction over 18 U.S. Code § 241 investigations and prosecutions. The Criminal Division is no longer involved in consultation or review of 18 U.S. Code § 241 investigations.80 The Criminal Division has accordingly advised states that “[i]n the case of a crime of violence or intimida- tion,” they should “call 911 immediately and before contacting federal authorities” because “[s]tate and local police have primary jurisdiction over polling places,”81 despite clearly applicable federal law. This is a mistake. With respect to the 2020 presidential election, there were no DOJ investigations of the appropriateness or lawfulness of state election guidance. Consider the state of Pennsylvania. The Secretary of State sent guidance to the counties stating that: This revised guidance addresses the issuance, voting and examination of provisional ballots under the Election Code. Provisional ballots were originally mandated by section 302 of the Help America Vote Act of 2002 (HAVA). Provisional ballot amendments included in Act 77 of 2019 went into effect for the 2020 Primary election. Provisional ballot amendments included in Act 12 of 2020 go into effect for the first time on November 3, 2020.82 HAVA, however, mandates provisional ballots only for eligible voters who were not on a state’s voter registration list.83 It does not apply to those who registered for mail-in voting but whose ballots were rejected due to some form of spoliation. — 564 — Mandate for Leadership: The Conservative Promise Pennsylvania Act 12 (amended in 2020) does not authorize curing by providing provisional ballots for mail-in voters whose ballots were rejected. Act 12 requires, as part of the mail-in application process, an affidavit that: [The elector] shall not be eligible to vote at a polling place on election day unless the elector brings the elector’s mail-in ballot to the elector’s polling place, remits the ballot and the envelope containing the declaration of the elector to the judge of elections to be spoiled and signs a statement subject to the penalties under 18 Pa.C.S. § 4904 (relating to unsworn falsification to authorities) to the same effect.84 The law in Pennsylvania clearly states that no county may affirmatively provide provisional ballots: The mail-in voter must vote in person and sign a new affidavit. In the 2020 election, the Pennsylvania Supreme Court recognized that “the Election Code contains no requirement that voters whose ballots are deemed inadequately verified be apprised of this fact. Thus, unlike in-person voters, mail-in or absentee voters are not provided any opportunity to cure perceived defects in a timely man- ner.”85 Given the Pennsylvania Secretary of State’s use of guidance to circumvent state law, the Pennsylvania Secretary of State should have been (and still should be) investigated and prosecuted for potential violations of 18 U.S. Code § 241. Investigations and prosecutions under 18 U.S. Code § 241 are currently within the jurisdictional oversight of the Civil Rights Division, not the Criminal Division.86 Only by moving authority for 18 U.S. Code § 241 investigations and prosecutions back to the Criminal Division will the rule of law be appropriately enforced. Rejecting Third-Party Requests for Politically Motivated Investigations or Prosecutions. The DOJ should reject demands from third-party groups that ask it to threaten politically motivated investigation or prosecution of those engag- ing in lawful and, in many cases, constitutionally protected activity. By acceding to such demands, the department risks diminishing its credibility with the American public. This risk is exacerbated by the fact that communications between govern- ment officials and third-party groups are generally unprotected by privilege and subject to disclosure, whether via subpoena to the third-party group or via request made pursuant to the Freedom of Information Act. These communications can even be made public voluntarily by the third-party group. A recent example illustrates the risks posed by such activity. On October 4, 2021, Attorney General Merrick Garland issued a memorandum to the Director of the FBI, the Executive Office for U.S. Attorneys, and the Assistant Attorney General, Criminal Division, calling on the FBI to work with each U.S. Attorney to “con- vene meetings with federal, state, local, Tribal, and territorial leaders” to discuss strategies for addressing “threats against school administrators, board members, teachers, and staff.”87 Subsequent reporting and investigation revealed that the

Department of Health and Human Services

Weak

Vector: 60%

Pages: 533-535AI Enhanced

AI Analysis:

"The bill addresses digital exploitation and non-consensual intimate imagery, which is unrelated to the Project 2025 HHS policy excerpts focused on healthcare regulations, abortion policy, civil rights in health programs, and related statutory provisions. There is no substantive overlap in subject matter or policy objectives."

Key themes:healthcarecivil rights

— 501 — Department of Health and Human Services 54. U.S. Department of Health and Human Services, Centers for Medicare and Medicaid Services, Office of Civil Rights, and Office of the Secretary, “Special Responsibilities of Medicare Hospitals in Emergency Cases and Discrimination on the Basis of Disability in Critical Health and Human Service Programs or Activities,” draft of Proposed Rule, January 14, 2021, https://www.hhs.gov/sites/default/files/infants-nprm.pdf (accessed March 17, 2023). 55. H.R. 26, Born-Alive Abortion Survivors Protection Act, 118th Congress, introduced January 9, 2023, https:// www.congress.gov/118/bills/hr26/BILLS-118hr26pcs.pdf (accessed March 17, 2023). 56. H.R. 7, No Taxpayer Funding for Abortion and Abortion Insurance Full Disclosure Act of 2023, 118th Congress, introduced January 9, 2023, https://www.congress.gov/118/bills/hr7/BILLS-118hr7ih.pdf (accessed March 17, 2023). 57. S. 401, Conscience Protection Act of 2021, 117th Congress, introduced February 24, 2021, https://www.congress. gov/117/bills/s401/BILLS-117s401is.pdf (accessed March 17, 2023). 58. U.S. Department of Health and Human Services, Centers for Medicare and Medicaid Services, and Office of the Secretary, “Nondiscrimination in Health Programs and Activities,” Notice of Proposed Rulemaking; Notice of Tribal Consultation, Federal Register, Vol. 87, No. 149 (August 4, 2022), pp. 47824–47920, https://www.govinfo. gov/content/pkg/FR-2022-08-04/pdf/2022-16217.pdf (accessed March 17, 2023). 59. Ibid., p. 47916. 60. The regulation was not finalized before the end of the Administration. U.S. Department of Agriculture, Food and Nutrition Services, “Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program (SNAP),” Proposed Rule, Federal Register, Vol. 84, No. 142 (July 24, 2019), pp. 35570–55581, https:// www.federalregister.gov/documents/2019/07/24/2019-15670/revision-of-categorical-eligibility-in-the- supplemental-nutrition-assistance-program-snap (accessed March 17, 2023). 61. 45 Code of Federal Regulations § 75.300(c) and (d), https://www.ecfr.gov/current/title-45/subtitle-A/ subchapter-A/part-75/subpart-D/subject-group-ECFR911e5e1a30bfbcb/section-75.300 (accessed March 17, 2023). 62. H.R. 1750, Child Welfare Provider Inclusion Act of 2021, 117th Congress, introduced March 10, 2021, https:// www.congress.gov/117/bills/hr1750/BILLS-117hr1750ih.pdf (accessed March 17, 2023), and S. 656, Child Welfare Provider Inclusion Act of 2021, 117th Congress, introduced March 10, 2021, https://www.congress.gov/117/bills/ s656/BILLS-117s656is.pdf (accessed March 17, 2023). 63. S. 3949, Trafficking Victims Protection Reauthorization Act of 2022, Public Law No. 117-348, 117th Congress, January 25, 2023, https://www.congress.gov/117/plaws/publ348/PLAW-117publ348.pdf (accessed March 17, 2023). 64. Kelsey Y. Santamaria, “Child Migrants at the Border: The Flores Settlement Agreement and Other Legal Developments,” Congressional Research Service In Focus No. IF11799, April 1, 2021, https://crsreports.congress. gov/product/pdf/IF/IF11799 (accessed March 17, 2023). 65. Report, Building a Happy Home: Marriage Education as a Tool to Strengthen Families, Social Capital Project Report No. 1-22, March 2022, p. 17, https://www.jec.senate.gov/public/_cache/files/3d102525-6f0d-48ed- 92f4-d71edd468ad6/building-a-happy-home.pdf (accessed March 17, 2023). The cover of the report reflects that the Social Capital Project is “[a] project of the Joint Economic Committee – Republicans.” 66. See, for example, Alan J. Hawkins, “Are Federally Supported Relationship Education Programs for Lower-Income Individuals and Couples Working? A Review of Evaluation Research,” American Enterprise Institute, September 2019, https://www. congress.gov/117/plaws/publ228/PLAW-117publ228.pdf (accessed March 17, 2023). 67. H.R. 8404, Respect for Marriage Act, Public Law No. 117-228, 117th Congress, December 13, 2022, https://www. congress.gov/117/plaws/publ228/PLAW-117publ228.pdf (accessed March 17, 2023). 68. Madison Marino, “Over 1,000 Safety Violations Mar Head Start. Children Deserve Better,” Heritage Foundation Commentary, November 10, 2022, https://www.heritage.org/education/commentary/over-1000-safety- violations-mar-head-start-children-deserve-better. 69. American Hospital Association v. Becerra, 596 U.S. ___ (2022), https://www.supremecourt.gov/ opinions/21pdf/20-1114_09m1.pdf (accessed March 17, 2023). 70. U.S. Department of the Treasury, Internal Revenue Service; U.S. Department of Labor, Employee Benefits Security Administration; and U.S. Department of Health and Human Services, Centers for Medicare and Medicaid Services, “Coverage of Certain Preventive Services Under the Affordable Care Act,” Notice of Proposed Rulemaking, Federal Register, Vol. 88, No. 22 (February 2, 2023), pp. 7236–7281, https://www. govinfo.gov/content/pkg/FR-2023-02-02/pdf/2023-01981.pdf (accessed March 17, 2023). — 502 — Mandate for Leadership: The Conservative Promise 71. 42 U.S. Code § 238n, https://www.law.cornell.edu/uscode/text/42/238n (accessed March 17, 2023). 72. U.S. Department of Health and Human Services, Health Resources and Services Administration, “Early Childhood Health,” last reviewed October 2022, https://mchb.hrsa.gov/programs-impact/focus-areas/early- childhood-health (accessed March 17, 2023). 73. American Pregnancy Association, “Having a Doula—What Are the Benefits?” https://americanpregnancy. org/healthy-pregnancy/labor-and-birth/having-a-doula/#:~:text=Other%20studies%20have%20shown%20 that%20having%20a%20doula,massage%20to%20reduce%20stress%20and%20anxiety%20during%20labor (accessed March 17, 2023). 74. S. 2372, VA MISSION [Maintaining Internal Systems and Strengthening Integrated Outside Networks] Act of 2018, Public Law No. 115-182, 115th Congress, June 6, 2018, https://www.congress.gov/115/plaws/publ182/ PLAW-115publ182.pdf (accessed March 17, 2023). 75. U.S. Department of Health and Human Services, “Securing Updated and Necessary Statutory Evaluations Timely,” Final Rule, Federal Register, Vol. 86, No. 11 (January 19, 2021), pp. 5694–5764, https://www.govinfo. gov/content/pkg/FR-2021-01-19/pdf/2021-00597.pdf (accessed March 22, 2023). 76. U.S. Department of Health and Human Services, Office of the Secretary, Office of the Assistant Secretary for Health, “Compliance with Statutory Program Integrity Requirements,” Final Rule, Federal Register, Vol. 84, No. 42 (March 4, 2029), pp. 7714–7791, https://www.govinfo.gov/content/pkg/FR-2019-03-04/pdf/2019-03461.pdf (accessed March 18, 2023). 77. U.S. Department of Health and Human Services, Office of the Secretary, Office of the Assistant Secretary for Health, “Ensuring Access to Equitable, Affordable, Client-Centered, Quality Family Planning Services,” Final Rule, Federal Register, Vol. 86, No. 192 (October 7, 2021), pp. 56144–56180, https://www.govinfo.gov/content/ pkg/FR-2021-10-07/pdf/2021-21542.pdf (accessed March 18, 2023). 78. S. 624, Title X Abortion Provider Prohibition Act, 118th Congress, introduced March 2, 2023, https://www. congress.gov/118/bills/s624/BILLS-118s624is.pdf (accessed March 18, 2023). 79. 50 U.S. Code Chapter 55, https://www.law.cornell.edu/uscode/text/50/chapter-55 (accessed March 22, 2023). 80. 18 U.S. Code § 13, https://www.law.cornell.edu/uscode/text/18/13 (accessed March 18, 2023). 81. Bowen v. American Hospital Association, 476 U.S. 610 (1986), https://tile.loc.gov/storage-services/service/ll/ usrep/usrep476/usrep476610/usrep476610.pdf (accessed 22, 2023). 82. U.S. Department of Health and Human Services, Office of the Secretary, “Notification of Interpretation and Enforcement of Section 1557 of the Affordable Care Act and Title IX of the Education Amendments of 1972,” Federal Register, Vol. 86, No. 99 (May 25, 2021), pp. 27984–27985, https://www.govinfo.gov/content/pkg/FR- 2021-05-25/pdf/2021-10477.pdf (accessed March 18, 2023). 83. U.S. Department of Health and Human Services, Office for Civil Rights, “HHS Notice and Guidance on Gender Affirming Care, Civil Rights, and Patient Privacy,” March 2, 2022, https://www.hhs.gov/sites/default/files/hhs- ocr-notice-and-guidance-gender-affirming-care.pdf (accessed March 18, 2023). 84. Heckler v. Chaney, 420 U.S. 821 (1985), https://caselaw.findlaw.com/us-supreme-court/470/821.html (accessed March 18, 2022). 85. U.S. Department of Health and Human Services, Office for Civil Rights, “Guidance to Nation’s Retail Pharmacies: Obligations Under Federal Civil Rights Laws to Ensure Access to Comprehensive Reproductive Health Care Services,” content last reviewed July 14, 2022, https://www.hhs.gov/civil-rights/for-individuals/ special-topics/reproductive-healthcare/pharmacies-guidance/index.html (accessed March 18, 2023). 86. H.R. 3103, “Health Insurance and Portability and Accountability Act of 1996, Public Law No. 104-191, 104th Congress, August 21, 1996, https://www.congress.gov/104/plaws/publ191/PLAW-104publ191.pdf (accessed March 18, 2023). 87. U.S. Department of Human Services, “HIPAA Privacy Rule and Disclosures of Information Relating to Reproductive Health Care,” content last reviewed June 29, 2022, (accessed March 18, 2023). See also “Protecting the Privacy and Security of Your Health Information When Using Your Personal Cell Phone or Tablet,” content last reviewed June 29, 2022, https://www.hhs.gov/hipaa/for-professionals/privacy/guidance/ cell-phone-hipaa/index.html (accessed March 18, 2023).

Department of Justice

Minimal

Vector: 60%

Pages: 596-598AI Enhanced

AI Analysis:

"The bill focuses on criminalizing non-consensual deepfake intimate imagery, while the Project 2025 excerpt discusses DOJ jurisdiction over voter fraud and election crimes; they address unrelated policy domains."

Key themes:unrelatedno overlap

Department of Education

Minimal

Vector: 59%

Pages: 365-367AI Enhanced

AI Analysis:

"The bill addresses digital exploitation and non-consensual intimate imagery, while the Project 2025 policy focuses on rescinding Title IX changes related to gender identity, athletics data collection, and student loan regulations. There is no thematic or policy overlap between the two."

— 332 — Mandate for Leadership: The Conservative Promise to create and collect data on a new “nonbinary” sex category (in addition to the current “male” or “female” sex categories) and to retire data collection that indi- cates the number of (1) high school–level interscholastic athletics sports in which only male and female students participate, (2) high school–level athletics teams in which only male or female students participate, and (3) participants on high school–level interscholastic athletics sports teams in which only male or only female students participate. These poorly conceived changes are contrary to law, fail to take account of student privacy interests and statutory protections favoring parental rights under the Protection of Pupils Rights Amendment, and jettison longstanding data collections that assist in the enforcement of Title IX. l The new Administration must quickly move to rescind these changes, which add a new “nonbinary” sex category to OCR’S data collection and issue a new CRDC that will collect data directly relevant to OCR’s statutory enforcement authority. Student Assistance General Provisions, Federal Perkins Loan Program, and William D. Ford Federal Direct Loan Program Final Regulations Effective July 1, 2023, the department promulgated final regulations addressing loan forgiveness under the HEA’s provisions for borrower defense to repayment (“BDR”), closed school loan discharge (“CSLD”), and public service loan forgive- ness (“PSLF”). The regulations also included prohibitions against pre-dispute arbitration agreements and class action waivers for students enrolling in institu- tions participating in Title IV student loan programs. Acting outside of statutory authority, the current Administration has drastically expanded BDR, CSLD, and PSLF loan forgiveness without clear congressional authorization at a tremendous cost to the taxpayers, with estimates ranging from $85.1 to $120 billion. l The new Administration must quickly commence negotiated rulemaking and propose that the department rescind these regulations. l The next Administration should also rescind Dear Colleague Letter (DCL) GEN 22-11 and DCL GEN 22-10 and its letters to accreditation agencies dated July 19, 2022, which are attempts to undercut Florida’s SB 7044, providing universities more flexibility on accreditation. Nondiscrimination on the Basis of Sex in Education Programs or Activities Receiving Federal Financial Assistance (Title IX) With its Notice of Proposed Rulemaking published on July 12, 2022, the Biden Education Department seeks to gut the hard-earned rights of women with its changes to the department’s regulations implementing Title IX, which prohibits — 333 — Department of Education discrimination on the basis of sex in educational programs and activities. Instead, the Biden Administration has sought to trample women’s and girls’ athletic oppor- tunities and due process on campus, threaten free speech and religious liberty, and erode parental rights in elementary and secondary education regarding sensitive issues of sex. The new Administration should take the following steps: l Work with Congress to use the earliest available legislative vehicle to prohibit the department from using any appropriations or from otherwise enforcing any final regulations under Title IX promulgated by the department during the prior Administration. l Commence a new agency rulemaking process to rescind the current Administration’s Title IX regulations; restore the Title IX regulations promulgated by then-Secretary Betsy DeVos on May 19, 2020; and define “sex” under Title IX to mean only biological sex recognized at birth. l Work with Congress to amend Title IX to include due process requirements; define “sex” under Title IX to mean only biological sex recognized at birth; and strengthen protections for faith-based educational institutions, programs, and activities. The Trump Administration’s 2020 Title IX regulation protected the founda- tional right to due process for those who are accused of sexual misconduct. The Biden Administration’s proposed change to the interpretation of Title IX disposes of these rights. l The next Administration should move quickly to restore the rights of women and girls and restore due process protections for accused individuals. At the same time, there is no scientific or legal basis for redefining “sex” to “sexual orientation and gender identity” in Title IX. Such a change misrepresents the U.S. Supreme Court’s opinion in Bostock, threatens the American system of federalism, removes important due process protections for students in higher education, and puts girls and women in danger of physical harm. Facilitating social gender transition without parental consent increases the likelihood that children will seek hormone treatments, such as puberty blockers, which are experimental medical interventions. Research has not demonstrated positive effects and long- term outcomes of these treatments, and the unintended side effects are still not fully understood.

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Policy matches are calculated using a hybrid approach: initial candidates are found using semantic similarity between bill summaries and Project 2025 policy text, then an AI model (Llama 3.1 70B) provides detailed alignment ratings and analysis. Ratings range from 1 (minimal alignment) to 5 (very strong alignment). This analysis does not imply direct causation or intent.

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Protect Victims of Digital Exploitation and Manipulation Act of 2025