Tony Comstock on the MPAA Ratings Board


Tony Comstock is the founder of Comstock Films (likely NSFW), which produces films that I can’t bring myself to call pornography, even though their central subject, depicted in explicit detail, is the sex that ordinary couples have in private.

The best term for his films is probably “documentary erotica,” since in addition to the sex happening on the screen, they also document the loving relationship underlying it, and — perhaps most importantly — the sex is not performative per se, but is a private act that happens to be photographed.

But that’s not the point of this post.

Here’s the point: recently, Comstock started a website, The Intent to Arouse,  where he investigates the legal background and business realities that shape the explicit depiction of sex in the cinema. His most provocative post to date (for me, anyway) is from July 4th, in which he defends the MPAA ratings board as being not quite so bad as  censorship boards in other “free” countries, such as Australia and Britain.

His argument is mostly directed against Kirby Dick’s powerful critique of the MPAA, This Film is Not Yet Rated, which contends that the MPAA keeps worthy films from audiences because the NC-17 rating — which is disproportionately applied to films that depict non-hetero sex, or hetero sex from the waist down, as opposed to extreme violence — guarantees limited distribution for the films thus rated. Comstock points out that “limited distribution” is nowhere near the same as “no distribution,” and he highlights the way that small-budget filmmakers use the MPAA rating as a marketing tool — as in, “this is the uncut version!”, a tactic that Trey Parker and Matt Stone famously parodied with the title of 1999’s South Park: Bigger, Longer and Uncut.

The comment stream is particularly revealing in this case, bringing up as an example one of Kirby Dick’s earlier films, Sick, from which he had to cut an important (if stomach-churning) scene in order to secure approval from the British censors — without cutting that scene, his film would have been denied distribution in the UK.

Jeremy Hatch is a writer, musician, and professional bookseller leading a cheerful, aimless life in San Francisco. He is the Junior Literary Editor of the Rumpus and has a blog which he updates once in a while. More from this author →